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Full text of "Overflow of gasoline and fire at a service station-convenience store in Biloxi, Mississippi on August 9, 1998"

PB99-917007 
NTSB/HZM-99/02 



NATIONAL 
TRANSPORTATION 
SAFETY 
BOARD 

WASHINGTON, D.C. 20594 

HAZARDOUS MATERIALS ACCIDENT REPORT 

OVERFLOW OF GASOLINE AND FIRE 

AT A SERVICE STATION-CONVENIENCE STORE 

BILOXI, MISSISSIPPI 

AUGUST 9, 1998 



For Reference 

Do Not Take 

From the Library 




National Transportation Safety Board. 1999. Overflow of Gasoline and Fire at a Service Station- 
Convenience Store, Biloxi, Mississippi, August 9, 1998. Hazardous Materials Accident Report 
NTSB/HZM-99/02. Washington, DC. 

Abstract: This report explains the gasoline overflow and resulting fire that occurred during a cargo transfer 
by Premium Tank Lines, Inc., to an underground storage tank at a Fast Lane gasoline station-convenience 
store in Biloxi, Mississippi, on August 9, 1998. The fire engulfed three vehicles at a nearby intersection, 
which ultimately resulted in the deaths of five occupants and the serious injury of one. Damages were 
estimated at $55,000. 

From its investigation of this accident, the Safety Board identified safety issues in the following areas: 
Premium Tank Line, Inc.'s management oversight; R.R. Morrison and Son, Inc.'s procedures for accepting 
petroleum product deliveries to underground storage tanks; and Federal requirements and oversight. Based 
on its findings, the Safety Board made recommendations to the Federal Highway Administration, the 
Research and Special Programs Administration, the Environmental Protection Agency, Premium Tank 
Lines, Inc., R.R. Morrison and Son, Inc., the American Petroleum Institute, the National Tank Truck 
Carriers Association, the National Association of Convenience Stores, the National Association of Truck 
Stop Operators, the Petroleum Marketers Association of America, the Service Station Dealers of America, 
and the Society of Independent Gasoline Marketers of America. 



The National Transportation Safety Board is an independent Federal agency dedicated to promoting 
aviation, raiload, highway, marine, pipeline, and hazardous materials safety. Established in 1967, the agency 
is mandated by Congress through the Independent Safety Board Act of 1974 to investigate transportation 
accidents, study transportation safety issues, and evaluate the safety effectiveness of government agencies 
involved in transportation. The Safety Board makes public its actions and decisions through accident 
reports, safety studies, special investigation reports, safety recommendations, and statistical reviews. 

Recent publications are available in their entirety at http://www.ntsb.gov/. Other information about 
available publications may also be obtained from the Web site or by contacting: 

National Transportation Safety Board 
Public Inquiries Section, RE-51 
490 L'Enfant Plaza, East, S.W. 
Washington, D.C. 20594 
(800) 877-6799 or (202) 314-6551 

Safety Board publications may be purchased, by individual copy or by subscription, from the National 
Technical Information Service. To purchase this publication, order report number PB99-917007 from: 

National Technical Information Service 
5285 Port Royal Road 
Springfield, Virginia 22161 
(800) 553-6847 or (703) 605-6000 



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Hazardous Materials Accident Report 

Overflow of Gasoline and Fire 

at a Service Station- Convenience Store 

Biloxi, Mississippi 

August 9, 1998 







NTSB/HZM-99/02 


"SjJV^ 


PB99-9 17007 


National Transportation Safety Board 


Notation 7 120A 


490 L'Enfant Plaza, S.W. 


Adopted: September 21, 1999 


Washington, D.C. 20594 



Hazardous Materials Accident Report 



Contents 



Executive Summary 



v 



Factual Information 1 

Accident Synopsis 1 

Accident Narrative 1 

Preaccident Events 1 

Events at Fast Lane Station No. 741 2 

Emergency Response 6 

Police Response 6 

Fire Department Response 6 

Injuries 6 

Damages 7 

Vehicle Information 7 

Hazardous Materials Information 7 

Facility Information 8 

General 8 

Other Overfills at Station No. 741 8 

Personnel Information 10 

Driver's Military Background 10 

Civilian Training and Work History 10 

Other Overfills by the Truckdriver 13 

Operating Violations 13 

Medical 14 

Work-Rest Routine 15 

Toxicological Testing 15 

Carrier Information 15 

General 15 

Hiring Procedures 16 

Training 17 

Safety Briefings 19 

Dispatch Procedures 19 

Transfer Procedures 20 

Carrier Oversight by the Federal Highway Administration 22 

Red Jacket™ Monitoring System 22 

Fast Lane Employee Training 23 



Contents iv Hazardous Materials Accident Report 

Environmental Protection Agency Requirements 23 

Safeguards Against Overfills 23 

Regulations Pertaining to Monitoring Transfers 23 

EPA State Program Approval 24 

Regulatory Enforcement 25 

Notification of Hazardous Materials Incidents 25 

Analysis 27 

General 27 

Exclusions 27 

Accident Analysis 27 

Adequacy of Premium's Management Oversight 28 

Hiring Practices 28 

Employee Training 31 

Adherence to Policy 33 

Dispatch Procedures 34 

Adequacy of Fast Lane Employee Training 35 

Adequacy of EPA Enforcement 36 

Accident Notification Requirements 36 

Conclusions 38 

Findings 38 

Probable Cause 39 

Recommendations 40 

Appendixes 

A: Investigation 43 

B: Driver-Trainer's Checksheet 44 

Abbreviations and Acronyms 47 



Hazardous Materials Accident Report 



Executive Summary 



On August 9, 1998, about 12:53 a.m., a Premium Tank Lines, Inc., truckdriver was 
transferring gasoline from a cargo tank to underground storage tanks at a Fast Lane 
gasoline station-convenience store in Biloxi, Mississippi, when an underground storage 
tank containing gasoline overflowed. An estimated 550 gallons of gasoline flowed from 
the storage tank, across the station lot into the adjacent highway, through an intersection, 
and into a storm drain. The gasoline ignited, and fire engulfed three vehicles near the 
intersection, which ultimately resulted in the deaths of five occupants and the serious 
injury of one. Damages were estimated at $55,000. 

The National Transportation Safety Board determines that the probable cause of 
the accident was the failure of Premium Tank Line, Inc.'s officials to follow established 
company procedures in hiring and training new drivers, the company's lack of adequate 
procedures for dispatching drivers and delivering cargo to customer facilities, and the 
failure of R.R. Morrison and Son, Inc., to have adequate safety procedures for accepting 
product offered for delivery at its Fast Lane stations. Contributing to the accident was the 
truckdriver's various and numerous operating errors during the gasoline transfer process 
that led to the underground storage tank overfill. 

The following safety issues are discussed in this report: 

• Premium Tank Line, Inc.'s management oversight; 

• R.R. Morrison and Son, Inc.'s procedures for accepting petroleum product 
deliveries to underground storage tanks; and 

• Federal requirements and oversight. 

As a result of its investigation of this accident, the Safety Board makes 
recommendations to the Federal Highway Administration, the Research and Special 
Programs Administration, the Environmental Protection Agency, Premium Tank Lines, 
Inc., R.R. Morrison and Son, Inc., the American Petroleum Institute, the National Tank 
Truck Carriers Association, the National Association of Convenience Stores, the National 
Association of Truck Stop Operators, the Petroleum Marketers Association of America, 
the Service Station Dealers of America, and the Society of Independent Gasoline 
Marketers of America. 



Hazardous Materials Accident Report 



Factual Information 



Accident Synopsis 

On August 9, 1998, about 12:53 a.m., a truckdriver for Premium Tank Lines, Inc., 
(Premium) was transferring gasoline from a cargo tank to underground storage tanks at a 
Fast Lane gas station-convenience store in Biloxi, Mississippi, when gasoline from one of 
the underground storage tanks began to overflow. An estimated 550 gallons of gasoline 
flowed from the storage tank, across the station lot into the adjacent highway, through the 
intersection, and into a storm drain. The gasoline ignited, and fire engulfed three vehicles 
near the intersection. Each of the three vehicles had two occupants. Of the six people, five 
sustained fatal injuries and one received serious injuries. Additionally, a firefighter 
dispatched to the accident site sustained minor injuries while attempting to suppress the 
fire. Damages were estimated at $55,000. 

Accident Narrative 

Preaccident Events 

Shortly after 5:30 p.m. on August 8, 1998, a Biloxi-based Premium truckdriver, in 
accordance with the company's operating practices, telephoned the weekend dispatcher at 
Premium's headquarters in Jackson, Mississippi, to obtain the assigned deliveries for his 
evening shift. The safety director, who was serving as dispatcher, told the truckdriver the 
delivery locations and the type and amount of gasoline to be delivered that evening. He 
said that he told the driver to make deliveries to the following Fast Lane stations: Nos. 
742, 743, and 736. The driver's notes indicated that he wrote down the following station 
numbers: 742, 743, and 741. ' The driver did not, nor was he required by written company 
procedures to, repeat or read back the information to the dispatcher to verify its accuracy 
during the telephone call. 2 

The Premium truckdriver departed Biloxi about 9:00 p.m. and drove his tractor- 
cargo tank trailer combination about 70 miles to the Shell Refinery in Saraland, Alabama, 
where he arrived about 10:08 p.m. He loaded one of the cargo tank's four compartments 
with 2,473 gallons of premium unleaded gasoline and the other three compartments with a 
total of 5,891 gallons of regular unleaded gasoline. He left the refinery at 10:23 p.m. 



1 The Premium dispatch records indicate that this same driver had made a delivery to Fast Lane station 
No. 741 on his shift that ended the morning of August 8; no delivery was scheduled to the station during his 
shift that ended on August 9. 

2 Premium did not have a policy of providing its drivers with confirmation of assigned deliveries by 
means of a written letter, facsimile, or electronic mail. Information about company policies appears later in 
this report. 



Factual Information 



Hazardous Materials Accident Report 



Events at Fast Lane Station No. 741 

Arriving at Fast Lane station No. 741 about midnight, the truckdriver parked the 
tractor cargo tank combination next to the remote fill ports (figure 1). Premium's 
operating practices require its drivers to present the bill of lading to the station operator 
before making the gasoline transfer. The truckdriver, however, did not do this. Drivers are 
also required to determine and document the gasoline level in an underground storage tank 
by inserting a graduated measuring stick that they carry on the cargo tank truck into the 
direct fill ports before and after transferring gasoline. This procedure, which drivers refer 
to as "sticking the tank," provides drivers with a product level reading in inches. 3 



Fast Lane station No. 741 has three underground storage tanks, which are indicated by the dotted line figures to 
the right of the gasoline pumps. One tank is for premium unleaded gasoline, one is for regular unleaded 
gasoline, and one is for diesel. Each of the tanks may be filled through either of two ports: a direct fill port 
located on the east side of the gas station property in a parking area or a remote fill port located on the south 
side of the property near the gas pumps. The direct and the remote fill ports are about 90 feet apart. 
Truckdrivers most often use the remote fill ports to transfer gasoline at the station. 




Grass Median 



U.S. Highway 90 (Beach Boulevard) 



Figure 1. Layout of accident site. The vehicles numbered 1 , 2, and 3 are, respectively, 
a 1995 four-door Hyundai sedan, a 1997 four-door Mazda sedan, and a 1999 
Ford pick-up truck. 



3 Because the sizes of storage tanks differ, the inch level of gasoline does not directly correlate with the 
number of gallons in a tank. The method drivers use to determine the number of gallons in a storage tank is 
discussed later in this report. 



Factual Information 3 Hazardous Materials Accident Report 

According to the truckdriver, he was able to stick the premium unleaded tank, but 
access to the regular unleaded direct fill port initially was blocked by a parked vehicle. He 
therefore went into the convenience store to obtain an inventory printout from the on-site 
Red Jacket™ system terminal. 4 He said that he did not know how to use the Red Jacket™ 
system so he asked for help from a Fast Lane employee. The store's assistant manager 
then generated a printout for him. Although the Red Jacket™ printout showed the gallons 
of gasoline and ullage 5 in each of the underground storage tanks, the driver later told 
Safety Board investigators that he did not fully understand the printout and that he had 
obtained it only for the inch reading that he was required to record on his paperwork. 6 

The truckdriver said that, upon exiting the store, he discovered that the vehicle 
blocking the direct fill port had moved. He was then able to stick the regular unleaded tank 
for his reading. He said that he did not use the inch readings to calculate the available 
space in the underground storage tanks. Instead, he relied solely on the information he had 
obtained earlier from the Premium dispatcher. After taking the inch readings, he did not 
replace the lids on the direct fill ports. 

The truckdriver told Safety Board investigators that he took the inch readings 
before he began transferring gasoline, that he hooked up the unloading hoses for both the 
premium and regular gasoline at the same time, and that he began unloading regular and 
premium simultaneously. The Red Jacket™ system printouts indicate the order of events 
listed in table 1. 

Station No. 741 's video surveillance system tape shows the truckdriver entering 
the station at 12:04: 14 a.m., walking to and from the restroom corridor, and then leaving at 
12:05:29 a.m. 7 The video tape shows the truckdriver reentering the store at 12:11:20, 
walking past the checkout counter, and then leaving the store at 12:18:01. 8 



4 The Red Jacket™ system is an automatic computer-based system that monitors the product levels in 
the underground storage tanks. Data from the Red Jacket™ system is transmitted to Premium's 
headquarters, which uses the information to determine the amount of product to be dispatched. Additional 
information about the Red Jacket™ system appears later in this report. 

5 Ullage is the amount by which a container lacks being full; in this case, the space above the liquid in 
the tank. 

6 On September 23, 1998, an independent contractor evaluated the Red Jacket™ system at station No. 
741 and concluded that, although the Red Jacket™ system was a good indicator of liquid levels in 
underground storage tanks, sticking a tank with an accurate measuring device was a more precise 
measurement method. 

7 The Red Jacket™ system and the video camera system were not synchronized. 

8 After viewing the video tape, store employees stated that they thought the truckdriver went into the 
room behind the checkout area where the automatic tank monitoring system printer was located. The 
truckdriver was identified on the video tape by the two store employees and by the customer who had alerted 
the truckdriver to the overflow. 



Factual Information 



Hazardous Materials Accident Report 



Table 1. Events recorded by Red Jacket™ computer-based monitoring system 


Time 


Event 


11:58:18 


Transfer of gasoline into premium gasoline tank begins 


12:16:39 


Inventory report generated [by Fast Lane assistant manager] 


12:17:44 


Transfer of gasoline into regular unleaded gasoline tank begins 


12:17:57 


Transfer of gasoline into premium gasoline tank ends 


12:40:21 


Transfer of gasoline into regular unleaded gasoline tank ends 



The truckdriver transferred the cargo compartment of premium unleaded gas and 
two of the three compartments of regular unleaded gas into the underground storage tanks 
without incident. During the transfer from the cargo tank's third compartment into the 
regular unleaded underground storage tank, a customer witnessed gasoline flowing from 
the direct fill port on the east side of the station property. (See figure 2.) The customer said 
that he saw the truckdriver standing near the cargo tank, seemingly unaware of the 
gasoline as it washed across the parking area in front of him. The customer described the 
gasoline stream as "several feet wide" and said that it "should have been visible to the 
truckdriver." The customer said that the truckdriver appeared to be "gazing" beyond the 
overflow "toward the casinos on U.S. Highway 90 (US 90)." The customer said that he 
told the truckdriver that gasoline was overflowing. The truckdriver then responded, 
"Okay, thanks," and closed a valve on the cargo tank to stop the flow. 



Restaurant 



Fast Lane 
Convenience Store 



-f 



Location of Driver 
During Overflow 



ft 



C 




. ] 




(Z 


Regular 

Jnleaded 


If 


dzm 




Direction of Gasoline Overflow 



U.S. Highway 90 (Beach Boulevard) 



Figure 2. Dotted lines from the regular unleaded underground storage tank to the storm 
drain represent the flow of the gasoline overfill. 



Factual Information 



Hazardous Materials Accident Report 



The customer said that when he returned from the convenience store to his car, he 
saw the truckdriver looking down at the transfer hoses. The truckdriver then climbed the 
ladder on the rear of the cargo tank, walked forward along the top of the tank, opened the 
manhole cover, and looked down inside the tank. 

The driver stated that after he was approached by the customer, he shut off the flow 
of regular unleaded gasoline from the cargo tank, walked to the open direct fill port to 
make sure it was no longer overflowing, and then climbed on top of the tank to assess the 
amount of gasoline remaining inside the cargo tank. 

About 550 gallons 9 of regular unleaded gasoline overfilled the underground 
storage tank. The excess gasoline flowed south from the open fill port through the gas 
station parking lot, then west along the north side of US 90 across the Brady Drive 
intersection, where it entered a storm drain under the highway. The drain emptied into an 
open concrete culvert, which ran southward toward the Gulf of Mexico. 

At the time of the overfill, three passenger vehicles, each of which had two 
occupants, were near the US 90-Brady Drive intersection. Two sedans were waiting in line 
to turn onto US 90, while an eastbound pickup truck was turning onto Brady Drive. Biloxi 
Police Department reports indicate that witnesses observed a fire ignite under one of the 
cars and engulf all three vehicles. (See figure 3.) The fire ultimately caused the fatal injuries 
of five occupants and the serious injury of one occupant. The fire, following the fuel flow, 
spread to the open fill port lid in the Fast Lane station and through the storm drain. 




Figure 3. One of the sedans and the pickup after emergency responders extinguished 
the blaze. The Premium cargo tank truck is in the background. 



9 Investigators determined how many gallons the station's underground tank and its associated piping 
would have held by identifying the pretransfer ullage. They next subtracted the gallons of regular unleaded 
gasoline left in the truck's cargo tank from the amount that had been loaded on the cargo tank to determine 
how many gallons had been pumped. They compared these figures to determine the overfill amount. 



Factual Information 



Hazardous Materials Accident Report 



Emergency Response 

Police Response 

About 12:53 a.m., a Biloxi police officer on routine motor patrol on US 90 
observed a large fire consume an automobile at the intersection of US 90 and Brady Drive. 
The police officer radioed for assistance, and additional officers arrived within the next 10 
minutes. The police evacuated a total of 80 people from the area, including the customers 
and staff from a restaurant at 2200 Beach Boulevard (US 90), a hotel on Brady Drive, and 
Fast Lane station No. 741. 

Fire Department Response 

At 12:53 a.m., a caller notified the Biloxi 911 operator that a person was on fire at 
the Fast Lane gas station. At 12:54 a.m., a Biloxi fire engine company was dispatched to 
the accident site, where it arrived about 12:59 a.m. In response to a second alarm at 12:56 
a.m., two engines, an aerial truck, and supervisory personnel were dispatched to the scene, 
arriving between 1:00 a.m. and 1:03 a.m. Responders established a command post on 
US 90, east of the fire scene. Fire units used about 50 gallons of foam and engaged in fire 
suppression and rescue operations until 1:40 a.m., when the fire was extinguished. 

Injuries 

Table 2 is based on the injury criteria of the International Civil Aviation 
Organization, which the Safety Board uses in accident reports for all transportation modes. 

Table 2. Injuries sustained in Biloxi, Mississippi, accident 





Drivers 


Passengers 


Others 


Total 


Fatal 


2 


3 





5 


Serious 


1 








1 


Minor 








1 


1 


None 


- 


- 


- 


- 


Total 


3 


3 


1 


7 


49 Code of Federal Regulations (CFR) 830.2 defines fatal injury as "any injury which results in death within 30 days of the 
accident" and serious injury as "an injury which: (1) requires hospitalization for more than 48 hours, commencing within 7 
days from the date the injury was received; (2) results in a fracture of any bone (except simple fractures of fingers, toes, 
or nose); (3) causes severe hemorrhages, nerve, or tendon damage; (4) involves any internal organ; or (5) involves 
second- or third-degree burns, or any burn affecting more than 5 percent of the body surface." 



Harrison County coroner records indicate that five of the six occupants of the 
vehicles died as a result of the fire. The Hyundai sedan operator, a 25-year-old male, 
sustained serious injuries and survived. The Mazda sedan passenger, a 20-year-old female, 
and the Ford pick-up truck passenger, a 56-year-old female, died at the accident scene. 
The Hyundai passenger, an 18-year-old male, the Mazda operator, a 43-year-old female, 
and the Ford operator, a 58-year-old male, died from their injuries after being admitted to 



Factual Information 



Hazardous Materials Accident Report 



area hospitals. A firefighter who received minor injuries was treated and released from a 
local hospital. 

Damages 

The convenience store, adjacent landscaping, restaurant signs, and cargo tank 
truck sustained minor thermal damage. Estimated damages totaled about $55,000 and 
included the value of the three destroyed passenger vehicles and the costs of repairing the 
truck tractor, of repairing and testing the cargo tank, and of reopening Fast Lane station 
No. 741. 

Vehicle Information 

The tractor of the semitrailer combination vehicle was a 1992 Freightliner. It was 
coupled to an elliptically shaped aluminum MC 306 cargo tank, which had been 
manufactured to Federal specifications in 1978 by Pullman Trailmobile of Chicago. The 
cargo tank had four separate compartments. Table 3 shows the capacity of each of the 
compartments and the total capacity of the cargo tank. 

Table 3. Capacity of cargo tank 



Compartment 


Capacity (gallons) 


1 (Forward) 


2,500 


2 


2,000 


3 


1,750 


4 (Aft) 


2,750 


Total 


9,000 



Premium company records and exterior markings on the front head of the cargo 
tank indicated that the cargo tank had been inspected and tested in accordance with 
Federal regulations. Following the accident, certified Mississippi Public Service 
Commission (MPSC) inspectors completed a CVSA 10 (Commercial Vehicle Safety 
Alliance) inspection on the tractor and the cargo tank and noted no defects that would have 
rendered them out of service before the accident. 

Hazardous Materials Information 

The U.S. Department of Transportation (DOT) classifies gasoline as a hazard 
Class 3 (flammable liquid). Gasoline has a flash point of -40° Fahrenheit, an auto ignition 
temperature of 500° Fahrenheit, and a flammable range of 1.3 to 7.6 percent in air. 



10 The CVSA is a body composed of Federal, State, and industry representatives who meet regularly to 
formulate uniform inspection procedures for commercial motor vehicles involved in the transportation of 
hazardous and nonhazardous cargoes. 



Factual Information 8 Hazardous Materials Accident Report 

Facility Information 

General 

At the time of the accident, Fast Lane station No. 741 was 1 of 55 gas station- 
convenience stores in Louisiana, Mississippi, and Tennessee owned by R.R. Morrison and 
Son, Inc., (Morrison) which is headquartered in Vicksburg, Mississippi. The station has 
three underground storage tanks, each with a capacity of 12,032 gallons. 

At most Fast Lane stations, each underground storage tank has one fill port 
through which gasoline is transferred. At four sites, however, each underground storage 
tank has two fill ports; one is a direct fill port, and the other is a remote fill port. Those 
sites are station No. 741 and stations in Bay St. Louis, Mississippi, Jackson, Tennessee, 
and Bastrop, Louisiana. Figure 4 illustrates a typical gas station that has both direct and 
remote fill ports. According to Premium officials and drivers, using the remote fill ports at 
station No. 741 for gasoline transfers affords drivers greater safety. Drivers said that they 
preferred to use the remote fill port at station No. 741 because doing so enabled them to 
drive forward to exit the site. If they use the direct fill port, they have to exit the station by 
backing onto US 90. 

Federal regulations contained in 40 CFR 280.20 require that underground storage 
tanks be equipped with safeguards to prevent spilling and overfilling during gasoline 
transfer. Morrison elected to install float valves (figure 4) in the tank vents of the Fast 
Lane station storage tanks. The float valve rises as gasoline fills the tanks, eventually 
seating against the end of the vent pipe and restricting the vapor flow through the vent 
pipe, which causes pressure to build. The pressure in the tank works against the head of 
the liquid in the cargo tank and the transfer hoses, causing a reduction in the flow of 
gasoline. Because the operation of a float valve is pressure controlled, at a station having 
both direct and remote fill ports, such as Fast Lane station No. 741, only one fill port 
should be open during a gasoline transfer. If a second fill port is open, the vapor can 
escape through it, rendering the float valve safety feature ineffective. 

Other Overfills at Station No. 741 

On July 15, 1996, a different Premium truckdriver was involved in an overfill of 
about 50 to 60 gallons at Fast Lane station No. 741. That truckdriver told Safety Board 
investigators that he was transferring gasoline through the remote fill ports when it began 
to overfill through the direct fill ports, which he had left open after gauging the 
underground storage tanks. This truckdriver told Safety Board investigators that he was 
not aware of any Premium document explaining transfers at facilities with remote fill 
ports. 



Factual Information 



Hazardous Materials Accident Report 



Gasoline transferred through the remote fill ports does not flow directly into the underground storage tanks 
but though pipes that extend at an angle from the port openings. Because of the angle of the pipes, 
measurements to gauge the amount of gasoline in the tank cannot be taken through the remote fill ports but 
must be made through the direct fill ports. 




At Fast Lane station No. 741, the Red Jacket™ monitoring system was designed to trigger an alarm 
whenever the gasoline level in a tank reached 90-percent capacity. 



The vent of the underground storage tank 
is equipped with a float valve, which is 
designed to rise as gasoline fills the tanks. 
At a predetermined level, the stainless 
steel ball float seats against the end of the 
vent pipe, restricting the vapor flow 
through the tank vent, which creates 
pressure in the underground tank that 
affects the flow of gas from the cargo tank. 
If the direct and the remote fill ports to an 
underground storage tank are both open 
during the gasoline transfer, the pressure 
will not build but will escape through the 
open fill port, which renders the float valve 
safety feature ineffective. 



. Fitted To 
Vent Line 





Float valve before 
gasoline rises 



Float valve after 
gasoline rises 



Figure 4. Top illustration is a cutaway of a typical service station having both direct and 
remote fill ports. Lower illustration shows a typical float valve, which was the 
type of safeguard against spills and overfills that the Morrison company had 
installed in many Fast Lane stations. 



Factual Information 10 Hazardous Materials Accident Report 

Personnel Information 

Driver's Military Background 

The truckdriver involved in the Biloxi accident was a 20-year veteran of the U.S. 
Navy who had retired from military service in 1997. He had graduated from high school 
before enlisting in the military. While in the Navy, he completed six college-level 
correspondence courses and, in 1994, military law enforcement school. His military skills 
list shows that, as of 1993, he had received training in operating or been awarded military 
licenses to operate the following vehicles: truck tractors and trailers, cranes and 
attachments, graders, crawlers, front-end loaders, forklifts, and buses. His military service 
history records show that, among other assignments, he had driven trucks and operated 
heavy equipment, including cargo cranes for unloading ships. 

His military records also indicate that he had been involved in a series of accidents 
that resulted in referrals for medical evaluation and, ultimately, his suspension from 
operating heavy equipment in 1989. He subsequently was transferred to maintenance 
duties. In 1991, his licenses were reinstated, and he served in northern Iraq during the 
Persian Gulf Conflict, making aircraft runway repairs and driving ambulances. From 1993 
until his retirement in 1997, he worked in maintenance services and security. His records 
show that his security duties consisted primarily of investigating mishaps, giving 
examinations for equipment operating licenses, dispatching security vehicles, and 
scheduling vehicle maintenance. 

His military personnel evaluations were favorable. Many contained comments 
from various supervisors on his accuracy and excellent work, his dedication to the Navy, 
and his care in observing military dress standards. With occasional exceptions, he was 
recommended for retention and for promotion. 

Civilian Training and Work History 

On July 27, 1997, the truckdriver enrolled, in a 6-week semitractor-trailer driving 
training course at the Commercial Driver Institute, Inc., (CDI) in Gulfport, Mississippi. 
He received a passing overall score of 86.95 percent for the class work and, on August 22, 
1997, was issued a Mississippi Commercial Drivers License (CDL) that included both a 
hazardous materials and cargo tank endorsement. 

While in training at the CDI, on August 4, 1997, the truckdriver applied for a job 
with Werner Enterprises, Inc., (Werner) of Omaha, Nebraska, an interstate freight carrier. 
Upon successful completion of his CDI training, Werner hired him. Company personnel 
records indicate that the driver's employment was terminated on September 12, 1997, 
during his training period for "not progressing as a trainee." His Werner personnel file 
contains two documents that deal directly with the cause for his dismissal. One document 
is a complaint and incident report stating that his driver-trainer found the truckdriver to be 
unsuitable and a "danger to himself and others." The other document, a "Driver-Trainee 



Factual Information 11 Hazardous Materials Accident Report 

Status Worksheet," indicates the driver was not progressing as a trainee and contains the 
annotation, "Driver has grossly unsafe instincts and practice(s)." 1 ' 

The truckdriver did not report his job with Werner on the applications for his next 
two jobs. 12 

After leaving Werner, the truckdriver was employed in September 1997 by John 
Fayard Fast Freight Trucking (Fayard) of Gulfport, Mississippi, as an over-the-road driver 
for van-type tractor-trailers. As required of all new Fayard drivers, he had a 1-week 
training class and an 8-week probationary period during which he was accompanied by a 
driver-trainer while on his routes. 

The driver- trainer observed that the truckdriver operated safely and characterized 
him overall as a "pretty good driver." He described the truckdriver as being conscientious 
about watching over his rig when it was parked and keeping his log book current and 
accurate. The driver-trainer noted that the truckdriver had problems with company 
paperwork, paying attention during training, noticing roadway signs, and backing the 
truck. He said that sometimes the truckdriver was "hard to reason with." On one occasion, 
the driver- trainer observed the truckdriver taking medication and asked him what it was. 
The truckdriver told him it was Ritalin. 13 The driver-trainer reported the incident to the 
company. Personnel records indicate that the truckdriver worked for Fayard as a regular 
driver for 5 months, until he quit without notice in April 1998. 

The truckdriver was hired by Premium on April 20, 1998. He received 6 days of 
training, which began with 1 day of company orientation that included information and 
two video tapes on hazardous materials. He was required to take a written examination on 
hazardous materials, which he passed. During the next 5 days, he was in an on-the-job 
training (OJT) status, during which he was accompanied by a driver-trainer on deliveries. 

The driver-trainer said the OJT began with the trainer performing the delivery 
work on the first day so that the new employee could see how things were to be done. 
During the rest of the OJT period, the truckdriver was supposed to perform the tasks while 
the driver-trainer observed and provided explanations or instructions as necessary. The 
driver- trainer told Safety Board investigators that he explained to the truckdriver how to 
convert inch readings to gallon figures using a tank chart and asked the truckdriver to let 



11 Safety Board investigators made numerous attempts to contact the Werner driver-trainer. He is no 
longer employed with the company and could not be located. Other Werner officials were unable to recall 
the specific details of the truckdriver's employment with the company. 

12 The truckdriver also did not disclose his employment with Werner during interviews with Safety 
Board investigators. The Safety Board obtained this and other information about the truckdriver from 
depositions taken later during civil proceedings. 

13 Ritalin is the brand name for methylphenidate hydrochloride, a mild prescription stimulant commonly 
used to treat attention deficit disorders (typically characterized by a history of chronic short attention span, 
distractibility, emotional lability, impulsivity, and moderate-to-severe hyperactivity) and narcolepsy 
(typically characterized by excessive daytime sleepiness with involuntary daytime sleep episodes, disturbed 
nighttime sleep, and sudden weakness). The most common adverse reactions to Ritalin are nervousness and 
insomnia. 



Factual Information 



12 



Hazardous Materials Accident Report 



him know if he wanted a copy of the tank charts. The driver-trainer said the truckdriver 
never asked for them. The truckdriver said that Premium never provided him with any 
charts or handbooks for determining whether the cargo tank load was greater than the 
available capacity of the receiving tanks. 

The driver- trainer told investigators that after he checked underground tank levels 
using the direct fill ports, he always ensured that he replaced the lids to the direct ports if 
he chose to use the remote fill ports for the gasoline transfer. He said that he had instructed 
the truckdriver to do the same. 

The driver-trainer said that, during the OJT period, the truckdriver sometimes took 
notes in a spiral notebook. Safety Board investigators found a spiral notebook in the cab of 
the accident truck. Most of the notebook's pages contain personal rather than work 
information. One page contains the notes shown in figure 5. 



Unloading Procedures 

1 . Stick tanks Get reading 

2. Open tank valves 

3. Remove caps 

4. Hook up hose 

5. Fill out bills/need manifest 

6. Make sure [to] send in a Fax on all Morrison loads 

On remote tank sick [sic] first The[n] use tank chart 
Customer gets green, yellow [and] blue 



Figure 5. Notes written in truckdriver's spiral notebook. 



During the OJT period, the driver- trainer and the truckdriver made two deliveries 
to Fast Lane station No. 741. The truckdriver's first visit to the station was on his second 
day of OJT, when, according to the training protocol, he was supposed to make the 
gasoline delivery while the driver-trainer oversaw his work. Instead, the driver went inside 
the convenience store for a sandwich while the driver- trainer made the transfer. The 
truckdriver made a delivery to station No. 741 on his last day of OJT. On this occasion, the 
driver-trainer noted no problems with the delivery. 

In his interview with Safety Board investigators, the driver-trainer described the 
truckdriver as "a nice guy" but said he was "hard to reason with" and "hard headed." He 
said that the truckdriver frequently did not pay attention when things were explained to 
him. He said that the truckdriver consistently demonstrated two operating problems, 
backing the cargo tank and unloading the gasoline at the stations. The driver-trainer 
indicated that after working with the driver for 4 days, he was going to "turn him down"; 
however, when he informed the safety director of his determination, the safety director 
told him to "take him out again." The driver-trainer said that, during the next day of OJT, 
he gave the truckdriver a "sharp lecture" about his lack of attentiveness before they began 
making deliveries, and the truckdriver performed well. When they returned to Premium's 



Factual Information 13 Hazardous Materials Accident Report 

headquarters that evening, the driver-trainer told the safety director about the truckdriver's 
improved performance. 

The next day was a Sunday. The truckdriver asked and was given permission to 
take off to attend church. The following day, Monday, the driver-trainer was off duty. 
When the truckdriver returned to work on Monday, the safety director told him that he 
could work alone. 

The driver-trainer told Safety Board investigators that he did not learn that the 
truckdriver had been allowed to work by himself until several days later. He said that he 
never approved the truckdriver's working alone, and he thought that he (the trainer) 
should have spent 2 or 3 more days with him to "go over everything again" to "ensure that 
things were clear in the driver's mind." The driver-trainer said that the safety director told 
him to complete and backdate the truckdriver's certificate and other materials showing 
that he had successfully completed the training so the truckdriver could be paid at the end 
of his second work week. The driver-trainer complied with the safety director's 
instructions and backdated the items to show that the driver had successfully completed 
the driver training program. 

The safety director said he hired the truckdriver because he had "a soft spot for 
vets" and preferred hiring career veterans over other applicants. The safety director said 
that his reason for instructing the truckdriver to make his first solo trip was that he needed 
a driver and the trainer had told him that the truckdriver had shown improvement on his 
last day of training. The safety director said that the truckdriver was allowed to continue 
working alone because everything went smoothly on his delivery run. 

Other Overfills by the Truckdriver 

Several weeks before the fire, the truckdriver overfilled an underground storage 
tank at the Bay St. Louis Fast Lane station. On this occasion, the truckdriver made the 
delivery to the correct facility. 

Like station No. 741, the Bay St. Louis Fast Lane station has both direct and 
remote fill ports, although they are much closer together. The incident occurred during the 
day, and the driver noticed the overfill after a small amount of gasoline (about 5 to 10 
gallons) overfilled. The truckdriver contacted Premium's Jackson office; and the 
operations manager, who was not aware that the Bay St. Louis station had remote fill 
ports, instructed him to climb on top of the cargo tank and determine how much of the 
load remained by looking into the cargo tank compartment. The operations manager 
directed the truckdriver to gauge all the receiving tanks and unload the rest of the gasoline 
into the premium unleaded underground storage tank. Morrison, the owner of the facility, 
maintained no records of the overfill at the Bay St. Louis Fast Lane station. 

Operating Violations 

The truckdriver's personnel file shows that, from May 5 to July 9, 1998, Premium 
officials noted 20 hours-of-service violations, including 15 70-hour violations, 3 10-hour 



Factual Information 14 Hazardous Materials Accident Report 

violations, and 2 15-hour violations. 14 According to Premium's safety director, the 
company issued the truckdriver three letters of reprimand for his violations. 

The Premium Tank Lines Driver's Manual (driver's manual) lists the following 
consequences for failing to comply with Bureau of Motor Carrier Safety 15 rules: 

First Offense - Letter of reprimand 
Second Offense - 3-day layoff 
Third Offense - 1-week layoff 

Premium's records do not indicate that the company pursued any action other than 
issuing disciplinary letters to the truckdriver for his infractions. 

Medical 

Federal Requirements. Title 49 CFR 391.41 states that drivers of commercial 
motor vehicles must be physically qualified and provides instructions for individuals 
performing and recording physical examinations. The regulations stipulate that a person 
who has a "mental, nervous, organic, or functional disease or psychiatric disorder that is 
likely to interfere with his ability to drive safely" is not qualified to drive a commercial 
vehicle. Federal regulations further stipulate that "the examining physician is required to 
certify that the driver does not have any physical, mental, or organic defect of such a 
nature as to affect the driver's ability to operate safely a commercial motor vehicle." 
Federal regulations do not require that physicians verify the information given by drivers 
during the examination. 

Driver's Medical Background. As noted earlier, while with the Navy, the 
truckdriver was referred for medical evaluation because he had been involved in a series 
of equipment operating accidents. Military physicians made a diagnosis of "attention 
deficit disorder" (ADD) and prescribed Ritalin for the condition. The medical records 
indicate that the truckdriver did well on the Ritalin. Nonetheless, as a result of a 
neurological evaluation in June 1989, Navy physicians made the following observation: 

It is recommended that this individual be cross-trained into some field 
where his attention deficits and visual-motor coordination problems will 
have less impact on his job safety and performance. 

Additionally, the truckdriver's military medical records note that he was referred 
for evaluation because "Co-worker reports patient sits and stares sometimes up to 15 
minutes." The military medical files do not contain the results of a CT scan, an EEG 
(electroencephalogram), or an MRI (Magnetic Resonance Imaging test) or physicians' 
comments indicating that the truckdriver had been the subject of such tests. 



14 For a 70-hour violation, the driver had to exceed 70 hours of driving and being on duty in an 8-day 
period. For a 10-hour violation, he had to exceed 10 hours of driving without an 8-hour break. For a 15-hour 
violation, he had to exceed 15 hours of being on duty and driving without an 8-hour break. 

15 The name of the Bureau of Motor Carrier Safety has been changed to the Office of Motor Carrier and 
Highway Safety (OMCHS). 



Factual Information 15 Hazardous Materials Accident Report 

Records indicate that after retiring from the Navy, the truckdriver received two 
DOT physical examinations: the first for his acceptance into the CDI, the second for his 
employment with Premium. Neither examination form indicates any type of psychiatric 
disorder or any other nervous disorder. The physician who performed the truckdriver's 
most recent medical examination said that he had no knowledge of the truckdriver's 
neurological history. 

At the time of the Biloxi accident, the truckdriver had a current medical card, and 
the only medical restriction on his personal operator's license and his CDL was for 
wearing corrective lenses while driving. His medical records indicate that he had myopia 
(nearsightedness) with astigmatism, which was corrected to 20/20 vision with glasses. 

Work-Rest Routine 

The truckdriver told Safety Board investigators that he was not fatigued on the 
morning of the fire. He had arranged with Premium to work the night shift. He said that he 
normally slept about 6 hours during the day, left for work about 9:00 p.m., and arrived 
back home between 8:00 and 9:00 a.m. His "Driver's Daily Log" indicates that on August 
5 to 7, he went on duty at 10:45 p.m., 11:00 p.m., and 7:15 p.m., respectively. On 
August 8, he said, he went to bed at 11:30 a.m. and awoke at 5:30 p.m., at which time he 
called the dispatcher. His shift that evening began at 9:00 p.m. 

Toxicological Testing 

Investigators found bottles of ginseng, aspirin, and "Bee Awake," a bee pollen 
product, in the truck cab after the accident. The truckdriver said that the bee product was 
intended to boost his energy. He said that he had taken one ginseng tablet, one aspirin 
tablet, and no other medication on the night before the accident. 

Biloxi police officials stated that, in anticipation of a possible criminal case, their 
personnel collected postaccident blood samples from the truckdriver and sent the 
specimens to the Mississippi State Crime Laboratory in Jackson. When the Safety Board 
became involved in the investigation, it asked that samples be forwarded to the Civil 
Aeromedical Institute (CAMI) in Oklahoma City for alcohol and drug testing. The 
analysis included testing to determine whether the truckdriver had taken Ritalin at 
therapeutic levels. The test results for alcohol, drugs, and Ritalin were negative. 

Carrier Information 

General 

Premium is a for-hire 16 motor carrier that primarily delivers petroleum products to 
storage tanks at service stations and other facilities. In addition to the drivers who work 



16 The DOT defines for-hire as "a person engaged in the transportation of goods or passengers for 
compensation." 



Factual Information 16 Hazardous Materials Accident Report 

out of the Jackson headquarters, Premium has cargo tank truckdrivers based in the 
following Mississippi cities: Collins, McComb, Meridian, Vicksburg, and Biloxi. 

Premium was formed and incorporated in 1986. In 1992, the company expanded to 
include trash and waste hauling. It sold all but one trash route in 1996. In 1997, Premium 
was hired by Morrison to monitor and fill underground storage tanks with gasoline and 
diesel fuel at selected Fast Lane gas stations. At the time of the accident, Premium 
serviced 12 Fast Lane stations along the Mississippi Gulf Coast, including station No. 741. 

As of mid-1998, Premium's petroleum distribution division employed 25 full-time 
drivers, 2 part-time drivers, and 7 office staff members; its fleet included 30 company- 
owned truck tractors, 13 owner-operator truck tractors, 54 company-owned cargo tanks, 
and 3 leased cargo tanks. Premium's waste hauling division employed 3 full-time and 2 
part-time drivers; its fleet had 6 truck tractors and 9 trailers, which were all company 
owned. 

Hiring Procedures 

Premium's safety director, who is responsible for hiring drivers, stated that 
Premium usually hires truckdrivers with about 2 years of over-the-road experience. 
Although the driver involved in the accident did not have 2 years of over-the-road 
experience, the safety director hired him because of his military background. 

Federal regulations at 49 CFR 391.23 require motor carriers to investigate a driver 
applicant's employment record during the preceding 3 years. Section 391.23(c) states: 

The investigation of the driver's employment record.... must be made 
within 30 days of the date his/her employment begins. The investigation 
may consist of personal interview, telephone interview, letters, or any other 
method of obtaining information that the carrier deems appropriate. Each 
motor carrier must make a written record with respect to each past 
employer contacted. 

The Premium safety director made the Federally required employment check with 
Fayard concerning the truckdriver. He said that he did not attempt to contact the military 
because he did not think it would be possible to obtain information. The safety director did 
not check with Werner because the truckdriver's employment application did not show his 
work experience with Werner. The safety director said that the truckdriver had the 
necessary licenses and his State motor vehicle record (MVR) did not reveal any violations. 
Premium hired the truckdriver after he passed a physical examination and drug screening. 



Factual Information 17 Hazardous Materials Accident Report 

Training 

Regulatory Requirements. Federal requirements contained in 49 CFR Subpart 
H, "Training," Section 172, stipulate that a hazardous materials (hazmat) employer 17 must 
ensure that (hazmat) employees 18 receive training and are tested on subjects in the 
following categories: general awareness and familiarization, function-specific, and safety. 

Highway-specific training requirements at 49 CFR 177.816 (b) stipulate that each 
person who operates a cargo tank be trained in a number of areas, including attendance to 
a hazardous materials vehicle and loading and unloading procedures. 

Overview of Premium's Program. Premium's driver training program, which 
spanned 1 to 2 weeks, began with a 1-day orientation taught by company officials at the 
Jackson headquarters. New drivers were shown several videotape presentations, including 
two tapes about hazardous materials, and were given a test on the information presented. 
Most of the orientation information was general in nature and included such topics as 
pretrip equipment inspections; required documents, stickers, and shipping papers; 
customer service; defensive driving; and emergency procedures. The instruction did not 
include discussions about how to transfer gasoline at stations, how to use tank charts, or 
how to determine the ullage in a tank. According to Premium's safety director, instruction 
directly related to gasoline transfers was handled by the driver-trainer who spent the 
remainder of the training period with the new employee and evaluated the trainee for 
suitability as a regular company driver. 

When a newly hired driver successfully concluded the training period, the new 
driver was issued a certificate of training completion signed by the driver-trainer that 
indicated the driver was prepared to work independently. The Premium Tank Lines' Driver 
Trainer Manual (trainer's manual) states that the driver-trainer is "the final decision- 
maker on whether or not the new hire will be a good, safe professional driver, capable of 
handling all the duties required...." 

Driver-Trainer Qualifications. Premium selected its driver-trainers based on their 
experience, knowledge of operations, and work record. The driver-trainer for the driver 
involved in the overfill had worked for petroleum companies since 1977 and Premium 
since 1987, when he joined the company as a lease operator. His background included 
several years as a dispatcher and extensive experience in tank operations. He had been a 
trainer of cargo tank truckdrivers for a previous employer; while at Premium, he had 
trained between 10 and 15 drivers. When not instructing new employees, the driver-trainer 
served as a full-time driver in Premium's coastal region. 



17 Section 171.8 states, in part, "a hazmat employer means a person who uses one or more employees in 
connection with: transporting hazardous materials in commerce." 

18 Section 171.8 states, "a hazmat employee means a person who is employed by a hazmat employer and 
in the course of employment directly affects hazardous materials transportation safety." The definition 
includes an individual who "loads, unloads, or handles hazardous materials" and who "operates a vehicle 
used to transport hazardous materials." 



Factual Information 18 Hazardous Materials Accident Report 

Premium's safety director said that, because of the driver-trainer's thoroughness, 
he had intentionally teamed him with the truckdriver. The driver- trainer told Safety Board 
investigators that he was knowledgeable about the subjects listed in the trainer's manual 
but that he did not have a complete understanding of the Red Jacket™ automatic tank 
gauging system. 

Training Materials. Premium's 37-page driver's manual, which is distributed to 
employees when they are hired, contains safety policies and general work procedures, 
including alcohol and drug policies and testing, emergency and accident procedures, 
defensive driving, and loading and unloading cargo. The driver's manual contains some 
safety requirements regarding unloading gasoline, including stipulations that a driver must 
stay in attendance while the unit is being unloaded 19 and must shut down the unloading 
process when away from the controlling valve. The driver's manual cautions, "Be sure 
you are at the right plant or station." The manual contains no guidance advising drivers 
how or when they should make this determination, but it does stipulate, "Before 
unloading, always get the consignee to check and sign your Bill of Lading." The driver's 
manual does not contain instructions for determining the ullage in underground storage 
tanks or a discussion of tank charts. 

The 17-page trainer's manual contains information on company practices, daily 
training activities, and lists general subjects that should be explained to truckdrivers 
during the training period. The trainer's manual does not state that the trainer should 
ensure that a new driver knows how to determine the ullage in underground storage tanks. 
Like the driver's manual, the trainer's manual states that drivers are to remain with the 
unit when gasoline is being unloaded. The driver- trainer told investigators that he had 
explained to the truckdriver the importance of staying with the unit when unloading. 

Neither manual contains specific instructions explaining safeguards against 
overfills or factors to consider when unloading gasoline at facilities with remote fill 
ports. 20 

In addition to the trainer's manual, each driver- trainer had a 2-page checksheet 
(appendix B) that lists subjects to review and critique during a new hire's OJT phase. Page 
one of the checksheet, at the top, has an area for remarks by the driver-trainer. The 
checksheet next has two blocks, one entitled "tractor" and the other "trailer," listing items 
to be explained by the driver-trainer to the new hire. Item 2 in the trailer block is "Where 
calibration charts are and how to use them." Premium officials stated that this reference is 
to the calibration charts that are used to determine the available space in the cargo tank. 

The remainder of the checksheet form contains 17 operating categories that the 
driver- trainer is to critique and check if the new hire does not perform the procedure 
satisfactorily. Most of the subjects deal with inspecting and operating the vehicle. 



19 Title 49 CFR 177.834 stipulates that a truckdriver must stay within 25 feet of the cargo tank during 
unloading. 

20 No Federal requirements stipulate that a hazmat employer or carrier have specific written procedures 
addressing loading and unloading gasoline. 



Factual Information 19 Hazardous Materials Accident Report 

Category XVI, "Loading and Unloading," has nine check items, including "Doesn't 
unload before checking address of customer with address on bill of lading" [item A]; 
"Doesn't break seals or unload until the customer has initialed bill of lading and inspected 
load" [item B]; and "Stays with unit; stands by product control valve (Driver controlled 
loading and unloading)" [item E]. 

Safety Briefings 

According to the company safety director, he travels to Premium's five bases of 
operations quarterly to conduct safety briefings with the truckdrivers assigned to those 
locations. He plans his briefings based on the kind of problems the company is 
experiencing. He said that recent briefings conducted before the Biloxi accident had 
focused on DOT regulations, driving habits, and paperwork, among other subjects. Two of 
the five Biloxi-based truckdrivers had experienced overfills before the accident discussed 
in this report. None of the five drivers recalled station overfills or stations with remote fill 
ports being discussed at company safety briefings in Biloxi. Before the August 9 accident, 
the safety director's last safety briefing in Biloxi had been on August 7. 

Dispatch Procedures 

Premium's customers order gasoline to be delivered in a variety of ways. Some 
customers monitor their own storage tanks and, when a delivery is necessary, telephone or 
fax a request to Premium's Jackson office. In the case of Morrison, it hired Premium not 
only to deliver gasoline but also to monitor the gasoline levels at selected Fast Lane 
service stations by means of a computer link between the Red Jacket™ system and 
Premium's headquarters computer system. 21 When data indicated that an underground 
storage tank needed to be filled, a Premium employee estimated the amount of gasoline to 
be sold to the station owner based on the present quantity of gasoline in the tank and the 
anticipated amount of gasoline that would probably be sold to the public before delivery 
could be made. As a safeguard against overfills, the Premium employee adjusted the 
amount of gasoline to be delivered to the underground tank based on 90 percent of its 
capacity. Headquarters personnel then prepared a master dispatch sheet assigning 
deliveries to the drivers, who obtained their assignments by telephone. 

According to the Premium operations manager, a miscalculation by Premium's 
headquarters personnel, slow retail sales at the gas station, or a maintenance problem at a 
station could result in too much gasoline being dispatched for a particular underground 
storage tank. 

The dispatch sheet indicates that, on the day before the accident, the same driver 
was dispatched to deliver 6,600 gallons of regular unleaded gasoline and 1,900 gallons of 
premium unleaded gasoline to Fast Lane station No. 741. Delivery reports verify that the 
underground storage tanks were filled during the early morning hours of August 8. 



Premium's computers use Pathway™ software to convert data from the Red Jacket™ system. 



Factual Information 20 Hazardous Materials Accident Report 

On the eve of the accident, the safety director was operating from his home and 
using a photocopy of the dispatch sheet to issue delivery assignments. He said that he 
directed the truckdriver to make the following deliveries to Fast Lane stations: No. 742 
(6,000 gallons regular and 2,500 gallons premium gasoline); No. 743 (6,000 gallons 
regular and 2,500 gallons premium gasoline); and No. 736 (6,000 gallons regular and 
2,500 gallons premium gasoline). He said that he did not learn that the truckdriver had 
gone to station No. 741 until he was contacted from the fire scene. 

The truckdriver stated that he wrote down what the safety director told him while 
they were still on the telephone. After the accident, in the truck cab, investigators found a 
small note on which was written the following: "742, 743, and 741; 31, 34, and 33, 22 and 
6000NL and 2500P." The truckdriver told Safety Board investigators that, although he had 
previously made deliveries to the same station twice in one day, he had never made 
deliveries that frequently to station No. 741. 

Both the safety director and the operations director indicated that they had made 
dispatch errors in the past; the safety director stated, however, that he was sure that he did 
not make an error on the evening of August 8. 

Since this accident, Premium has sent its dispatchers a memorandum outlining the 
operating changes that are being incorporated into the company's dispatch functions. 
Under "Procedures," the revised operating manual will stipulate: 

A. Dispatcher will give drivers instructions concerning products, amounts, 
customer location, etc., in written form whenever possible, (via 
personal written or fax) 

B. When it is not possible to provide written instructions to the driver, the 
dispatcher will give the instructions to the driver no less than two (2) 
times, then will require the driver to repeat the instructions to be sure 
the instructions have been communicated clearly. 

Transfer Procedures 

The Safety Board interviewed all five Biloxi-based true kdri vers regarding gasoline 
transfer procedures, in particular, about determining the ullage in an underground tank and 
making deliveries at stations with remote fill ports. 

Calculating Existing Ullage. The Premium driver's manual states, "Before 
unloading, always get the consignee to check and sign your Bill of Lading. By so doing, 
you are protecting yourself and your company." Neither the driver's manual nor the 
trainer's manual lists a standard procedure for calculating the volume of the underground 
storage tanks. 



"The numbers 31, 34, and 33, which represent the line numbers on the dispatch sheet, show the 
scheduled deliveries for Gulfport Fast Lane station No. 742, Biloxi Fast Lane station No. 743, and Long 
Beach, Mississippi, Fast Lane station No. 736. 



Factual Information 21 Hazardous Materials Accident Report 

Drivers convert the stick readings of underground storage tanks levels from inches 
to gallons by using the appropriate calibration chart, also called a tank chart. 23 By 
subtracting the gallons of gasoline in the tank from its total storage capacity, drivers can 
determine the available space. They can then compare this gallon figure to that shown on 
their shipping papers to determine whether the total amount of gasoline loaded on the 
cargo tank will fit into the underground storage facility. According to a Morrison official, 
each Fast Lane station maintains tank charts specific for that facility. 

Four of the five Biloxi-based Premium drivers stated that, based on their 
experience, they could generally tell from the "stick readings" whether the tank would 
hold the gasoline to be delivered. Most said that they checked the tank charts only if the 
stick reading indicated that the delivery might nearly fill the tank to capacity. Two of the 
drivers had obtained charts for each of the different sized tanks to which they delivered. 
The third driver, who was the truckdriver's driver- trainer, had most of the tank charts; the 
fourth driver did not carry any charts. The driver who did not carry tank charts said that if 
he had a question about the delivery, he either asked the service station personnel or called 
the dispatcher. 

The truckdriver involved in the accident (the fifth Biloxi-based driver) said that he 
never used a tank chart to figure the available space in the underground storage tank. He 
told investigators that he did not consider it his responsibility to know how much was in 
the tanks and that he thought he was required to stick the tanks to obtain a figure for 
billing purposes, not for assessing the space available in them. He said that, when making 
gasoline transfers, he relied solely on Premium's telephonic dispatch to provide the correct 
amount of gasoline and the station location. 

Using Remote Fill Ports. Neither the driver's manual nor the driver- trainer 
manual lists a standard procedure for transfer at facilities that have both direct and remote 
fill ports. 

The four other Biloxi-based truckdrivers told investigators that insect nests and 
other debris occasionally clogged the storage tank vents at station No. 741, making 
gasoline transfers difficult. The driver-trainer and another driver said that they always 
replaced the lids before a gasoline transfer. One driver said that he occasionally left the 
lids off if the transfer was slow. 24 The fourth driver, who was the Premium employee 
involved in the July 15, 1996, overfill at station No. 741, stated that he had never been told 
a specific procedure for delivering to stations with remote fills. He said that dirt dauber 25 
nests occasionally plugged vents at station No. 741 and that leaving the lid off the direct 
fill port made the gasoline transfer easier. After his overfill at the station, however, he was 



23 Tank charts differ depending on the volume of the tank and list both an inch reading and an equivalent 
gallon figure. 

24 By opening the second port during the gasoline transfer, the pressure that slows the gasoline flow will 
not build but will escape through the open fill port. 

25 Dirt daubers, also called mud daubers, are wasps that build nests of mud for their larvae. 



Factual Inform ation 22 Hazardous Materials Accident Report 

careful to replace the lids before every transfer. He said that if he found the vents to be 
clogged, he would contact the facility owner. 

Carrier Oversight by the Federal Highway Administration 

An OMCHS inspector last performed a complete review of Premium in June 1992. 
During the compliance review, the inspector took a sampling of 154 duty status records 
and identified 6 hours-of-service violations in the records reviewed. The agent 
recommended that Premium "Ensure all employees involved in handling hazardous 
materials shipments are properly trained and familiar with the regulations applicable to 
their jobs in the hazardous materials transportation system." 26 Premium received a 
satisfactory 21 rating as a result of the review and has not been the subject of a complete 
OMCHS audit since 1992. 

Red Jacket™ Monitoring System 

According to product literature, the Red Jacket™ underground storage tank 
monitoring system is used for complete leak detection and inventory management of 
underground storage tanks containing petroleum-based gasolines. The Red Jacket™ 
system was linked to computers at Premium, which used the Pathway™ software to 
extrapolate data and to determine the deliveries at some Fast Lane stations, including 
station No. 741. 

Each station equipped with the Red Jacket™ system has a remote terminal that 
prints different types of reports, including inventory, delivery, tank leak detection, and 
alarms. Each of these reports includes the date, time, station information, report name, 
tank number, gasoline type, and tank capacity. Reports may be scheduled, event-driven, or 
initiated by the key pad. 

The Red Jacket™ system has a feature that sounds an alarm inside the convenience 
store for a number of reasons, including when an underground storage tank reaches 90- 
percent capacity. The monitoring system does not have the capability to shut down a 
gasoline transfer when the alarm activates. The station's assistant manager described the 
alarm as a "mild beep" that lasts 2 to 3 seconds and then shuts off. She said that she 
typically heard the Red Jacket™ alarm about twice a month when deliveries were made. 
She indicated that, over the months, she had become accustomed to the alarm sound and 
usually did not respond to it any longer. Although the Red Jacket™ system printout 
indicates that an alarm sounded when the gasoline level in the underground tank reached 



26 Safety Board investigators questioned the agent, who no longer works for the OMCHS, regarding 
Premium's compliance review. Due to the passage of time, she could not remember many specifics of the 
audit but did remember the hours-of-service violations. Regarding her recommendation for hazardous 
materials training, she stated that she could not remember a problem with the training. She said that she 
often listed recommendations in review areas where she did not discover a violation, adding, "There is 
always room for motor carriers to evaluate areas of their program and make improvements." 

27 Motor carriers may receive a satisfactory, a conditional, or an unsatisfactory rating based on the 
OMCHS evaluation. 



Factual Information 23 Hazardous Materials Accident Report 



90-percent capacity on the day of the accident, neither of the two Fast Lane employees 
then on duty recalled hearing the beep. They said that they were busy stocking or were 
with customers in the convenience store. 

Following the accident, an independent contractor conducted an evaluation of the 
Red Jacket™ system and noted no significant problems with it. 28 

Fast Lane Employee Training 

The Fast Lane chain owner and the convenience store clerks working at the time of 
the accident stated that Fast Lane employees do not receive any specific training for 
monitoring or responding to the Red Jacket™ system for gasoline dispatch and transfer. 
Station employees are trained to use the Red Jacket™ system primarily to complete 
inventory and other paperwork requirements. Station employees are not trained to respond 
to the overfill alarm. 

The Fast Lane chain owners indicated that station employees usually signed the 
driver's paperwork following a gasoline delivery. The station employees stated that 
sometimes they were not aware that a delivery had been made until the driver entered the 
store for signature. 

Environmental Protection Agency Requirements 

Safeguards Against Overfills 

Federal regulations enacted by the Environmental Protection Agency (EPA) in 
1988 require that underground storage tanks be equipped with a means of preventing 
overfills and spills. As defined by 40 CFR 280.12, an overfill release occurs when a tank 
is filled beyond its capacity, resulting in a discharge of the regulated substance to the 
environment. Spilling is a release of hazardous materials that "results from improper 
dispensing practices such as disconnecting the delivery hose from the tank's fill pipe 
before the hose has drained completely." 29 Federal regulations at 40 CFR 280.20 require 
that underground storage tanks be equipped with safeguards to prevent spilling and 
overfilling during gasoline transfer. The EPA regulations list several acceptable safeguard 
devices or methods that owners can use. The Morrison company elected to install float 
valves in the underground tanks at its Fast Lane stations. 

Regulations Pertaining to Monitoring Transfers 

Title 40 CFR 280.30 (a), "Spill and overfill control," stipulates that 



28 The contractor found that the amount recorded by the monitoring system was slightly greater than the 
actual amount of product in the underground tanks. 

29 "Analysis of Today's Rule," Federal Register, Vol. 53, No. 185, p. 37133, published September 23, 
1988. 



Factual Information 24 Hazardous Materials Accident Report 



Owners and operators must ensure that releases due to spilling or 
overfilling do not occur. The owner and operator must ensure that the 
volume available in the [underground storage] tank is greater than the 
volume of product to be transferred to the tank before the transfer is made 
and that the transfer operation is monitored constantly to prevent 
overfilling and spilling. 

In response to the 1988 rulemaking, operators of certain facilities, such as tank 
farms, indicated that constant direct monitoring would be extremely difficult. The EPA, 
therefore, changed the final rule to allow monitoring with remote equipment. 

In its analysis of the rule, the EPA took the position that the owner of the 
underground storage system is responsible for any release. The analysis states: 

Although EPA agrees that responsible carriers are the primary agents in the 
field to prevent spills and overfills, for the purpose of complying with 
today's requirements, the UST [underground storage tank] system owner 
and operator is responsible for preventing spills and overfills. The agency 
must take this approach because it has no legal authority to regulate 
transporters under Subtitle I. Thus, regardless of whether the owner and 
operator decides to share (by contract) responsibility for the monitoring of 
the transfer with the carrier, under today's final regulations the owner and 
operator will continue to be responsible in the event that there is a release 
during delivery. 

EPA State Program Approval 

In discussing the challenges for compliance, the EPA stated that a regulatory 
program of underground storage systems can best be carried out by "those closest to the 
problem, who can respond quickly, and who can create a visible presence, that is, the State 
and local governments." Toward this end, the EPA initiated a process of examination, 
called the State Program Approval, in which Federal EPA officials review State 
underground storage tank regulations to determine that they are "no less stringent" than 
Federal law. The criteria for the no-less-stringent determination include general operating 
requirements stipulating, in part, that all underground storage systems: 

prevent spills and overfills by ensuring that the space in the tank is 
sufficient to receive the volume to be transferred and that the transfer 
operation is monitored constantly. 

State or local agencies whose regulations meet Federal requirements are accorded 
the primary responsibility for implementing and, when necessary, enforcing underground 
storage tank regulations. To date, the District of Columbia, Puerto Rico, and 27 States, 
including Mississippi, have been granted enforcement authority under the EPA State 
Program Approval. In Mississippi, the Mississippi Department of Environmental Quality 
(DEQ) serves in this capacity. According to EPA and DEQ representatives, Mississippi 
adopted verbatim the Federal regulations related to underground tank storage safety, 
including the requirements for overfill protection. 



Factual Information 25 Hazardous Materials Accident Report 

Regulatory Enforcement 

In States that have EPA State Program Approval, the EPA relies primarily upon 
State agencies to enforce regulations, although EPA inspectors may also enforce the 
regulations. According to the EPA's Office of Underground Storage Tanks (UST), Federal 
and State inspectors enforce underground storage tank regulations by various means, 
including warnings or fines, depending upon the severity of the violation. EPA officials 
indicated that in the agency's oversight of underground storage tanks, it has focused on 
equipment safeguards and preventing underground storage tank leaks. 

The Mississippi DEQ has four inspectors who regulate about 10,000 underground 
storage tanks, of which about 8,500 are currently in use and about 1,500 are temporarily 
out of use. Mississippi DEQ officials indicated that, based on available staff and funding, 
its inspectors visit a facility about every 4 years. Before the August 1998 accident, 
Mississippi DEQ representatives last inspected the underground storage tanks at station 
No. 741 in December 1997 and noted no significant violations at that time. After the 
accident, DEQ inspectors performed a visual inspection of the site to determine whether 
the top of the tank had loose fittings that may have caused or contributed to the release 
from the underground storage system. They found that all the fittings appeared to be tight. 

Interviews with Mississippi DEQ officials indicated that the State has not enforced 
requirements that facility owners in Mississippi determine available underground storage 
space or monitor product transfers. Moreover, the State has not cited any facility owners 
for violating 40 CFR 280.30 (a). 

For this investigation, the Safety Board contacted the acting director of the EPA's 
Office of UST to determine the scope of enforcement of 40 CFR 280.30 (a) by EPA 
investigators. The UST official surveyed EPA regional directors, of whom none could cite 
any specific case of enforcement. 

Notification of Hazardous Materials Incidents 

Soon after the fire erupted, the truckdriver notified the Premium safety director, 
who immediately drove from Jackson to the accident scene, a distance of about 170 miles. 
The safety director later stated that he maintained a telephone list of agencies to contact in 
the event of an emergency and that he made several unsuccessful attempts to report the 
accident to the National Response Center (NRC) while he was at the accident scene 
throughout the day. He said that he then drove back to his home in Jackson, where he fell 
asleep. When he awoke about 9:00 p.m., he remembered that he had been unsuccessful in 
reporting the accident and again tried to telephone the NRC with no success. He said that 
he then left his residence and drove to the Premium headquarters to check the phone 
number. At the office, he discovered that the number he had been using was incorrect, 
whereupon he called the NRC, which recorded the notification at 12:22 a.m. eastern 
standard time, 30 about 23 hours after the accident occurred. 



11:22 p.m. central standard time in Jackson. 



Factual Information 26 Hazardous Materials Accident Report 

Title 49 CFR 171.15, "Immediate notice of certain hazardous materials incidents," 
requires that motor carriers who transport hazardous materials report by telephone 
incidents meeting specified criteria, including a fatality, to the NRC "at the earliest 
practicable moment." In the October 1969 proposed rulemaking on accident reporting 
requirements, the Research and Special Programs Administration (RSPA) stated: 

The immediate report would cover the essential items of information 
necessary for the operating administrations of the Department and the 
National Transportation Safety Board to determine what immediate action 
should be taken by them, if any. 31 

In March 1999, RSPA published an Advance Notice of Proposed Rulemaking 
(ANPRM) to determine the need for regulatory changes to the reporting requirements of 
the hazardous materials contained in 49 CFR Part 171. 

In its June 1999 response to RSPA's ANPRM, the Safety Board cited three 
accidents involving transportation-related unloading operations that demonstrated 
deficiencies in the existing telephonic notification and incident requirements contained in 
49 CFR Part 171. The Safety Board included the August 9, 1998, Biloxi accident as an 
example, stating: 

Although the accident occurred about 1:00 a.m. on August 9, 1998, the 
motor carrier did not notify the NRC until nearly 24 hours after the 
accident. The delayed notification precluded the Safety Board and other 
Federal agencies... from responding promptly and initiating the accident 
investigation. 

The Safety Board further noted: 

Under reporting criteria at 49 CFR 171.15, a carrier who transports 
hazardous materials is required to provide telephonic notification 'at the 
earliest practicable moment.' However, during its investigation of the 
Biloxi accident, the Safety Board has noted that the term 'the earliest 
practicable moment' is not defined in the Hazardous Materials 
Regulations, nor has RSPA issued an interpretation that provides any time 
constraints on the reporting time frame. The Safety Board itself requires 
railroads under 49 CFR 840.3 to provide telephonic notification through 
the NRC not later than 2 hours after an accident resulting in a fatality, the 
release of hazardous materials, or evacuation of the public and not later 
than 4 hours after an accident resulting only in damages exceeding 
specified thresholds. The Safety Board believes that the effectiveness of 
the requirements for telephonic notification should be strengthened and a 
specific time frame given for providing telephonic notifications. 

In related matters, the Occupational Health and Safety Administration (OSHA), 
requires notification within 8 hours of the death or in-patient treatment of any employee 
following a work-related accident. 32 



31 Federal Register, Vol. 34, No. 208. Published October 29, 1969. Page 17450. 

32 29 CFR 1904.8 



27 Hazardous Materials Accident Report 



Analysis 



General 

This analysis is divided into three main sections. In the first part, the Safety Board 
identifies factors that can be readily excluded as causal or contributory to the accident. In 
the second section, the Board provides a synopsis of events directly leading to the 
accident. In the final section, the Board discusses deficiencies in three major areas that 
were identified as issues during this investigation: 

• Premium's management oversight; 

• Morrison's procedures for accepting petroleum product deliveries to 
underground storage tanks; and 

• Federal requirements and oversight. 

The issue of Federal requirements and oversight includes regulatory requirements 
relating to written procedures for loading and unloading cargo tanks transporting 
hazardous materials, the regulatory requirements for notifying Federal agencies of a 
hazardous materials incident, and the EPA's enforcement of the regulatory requirements 
contained in 40 CFR 280.30 (a) for preventing overfills. 

Exclusions 

The toxicological test results of blood samples taken from the truckdriver were 
negative for alcohol and drugs. The driver's work-rest schedule did not require alternate 
night and day sleeping, which probably neutralized the effect of his working early 
morning hours. In the 4 days before the accident, he reportedly obtained his normal 
amount of rest. Based on these findings, the Safety Board concludes that the Premium 
truckdriver was not impaired by drugs, alcohol, or fatigue on the morning of the Biloxi 
accident. 

Accident Analysis 

On the eve of the accident, the truckdriver telephoned the Premium dispatcher to 
obtain the assigned deliveries for his shift. The safety director, who was serving as 
dispatcher, orally provided the driver with a list of three delivery locations and the number 
of gallons to be delivered to each site. He said that he told the driver to make deliveries to 
Fast Lane station Nos. 742, 743, and 736. The driver said that he wrote down the delivery 
sites that the safety director had given him. His notes matched all of the dispatch line 
numbers and two of the station numbers (742 and 743). However, station number No. 741 
is listed rather than station No. 736. The dispatcher did not ask the driver to read the list to 
him to verify that he had understood and correctly recorded the delivery assignments. The 
dispatcher also did not provide a fax or written dispatch record to the driver. 



Analysis 28 Hazardous Materials Accident Report 

After picking up his load of gasoline, the truckdriver went to Fast Lane station No. 
741, which was not scheduled to receive a delivery. When the cargo tank truck arrived at 
the station, the Fast Lane station employees did not compare the amount of gasoline 
scheduled for delivery to the amount that the Red Jacket™ monitoring system indicated 
was in the underground tanks. Morrison, the station owner-operator, did not train and 
require its employees to monitor the volume of gasoline in underground tanks or to confer 
with cargo tank drivers to ensure the accuracy of deliveries; such a comparison, in this 
case, would have shown that the driver was in error and could have prevented the overfill. 

Once at the station, the driver made a number of operating errors. He did not 
determine the quantity of gasoline in the underground storage tanks, and he did not 
calculate the amount of gasoline that could safely be transferred from the cargo tank to the 
station storage tanks. After sticking the underground storage tanks through the direct fill 
ports, he failed to use the measurement that he obtained to calculate the available space for 
gasoline in the storage tank. He then failed to close the lids of the direct fill ports before 
beginning the gasoline transfer through the remote fill ports. Having both the remote and 
the direct port fill lids open rendered the tank system's pressure-controlled safety device 
ineffective and resulted in gas overflowing the direct fill port of the regular unleaded 
gasoline storage tank. 

Finally, the truckdriver did not properly monitor the gasoline transfer. The Red 
Jacket™ printout and the convenience store video tapes indicate that he left the cargo tank 
truck while gasoline was being transferred into the underground tanks, which was contrary 
to company procedures. When he was standing by the cargo tank, he did not notice the 
gasoline overflowing from the storage tank and streaming across the station lot. A 
customer at the station observed him gazing across the road, seemingly unaware of the 
gasoline near him. 

The stream of gasoline ran along the side of the road and across the intersection, 
which, at the time, was occupied by three passenger vehicles. A fire erupted under one of 
the vehicles and immediately engulfed all three. Five of the occupants in the vehicles 
sustained fatal injuries, and one occupant suffered serious injuries. 

Adequacy of Premium's Management Oversight 

Hiring Practices 

The Safety Board examined the truckdriver's performance in the context of 
information obtained from his past personnel and medical files and from observations by 
OJT personnel and noted some factors that should have prompted greater scrutiny during 
the hiring process. The Safety Board then looked at Premium's screening process for new 
applicants and noted some deficiencies. 

Medical Condition of the Truckdriver. Navy records indicate that the truckdriver 
was referred for medical evaluation and that several of his military-issued equipment 
operating licenses had been suspended after he had a series of equipment-related 
accidents. His Navy medical records indicate that military physicians diagnosed him as 



Analysis 29 Hazardous Materials Accident Report 

having ADD. His records show that after he was prescribed Ritalin, his condition 
improved and his licenses were restored. 

The truckdriver's actions during his civilian jobs were consistent with a medical 
condition such as ADD. During his training at Fayard and Premium, his driver-trainers 
complained that he frequently seemed preoccupied, was inattentive during instruction, and 
was easily distracted. 

The neurological condition described in the truckdriver's Navy medical records 
may explain his reaction to the Biloxi gasoline overfill. According to a witness, the 
overfill was in clear view of the truckdriver as he stood near his vehicle. However, the 
truckdriver was observed staring over the overfill and did not respond until the witness 
spoke to him. A more thorough assessment of the truckdriver's behavior cannot be offered 
without current neurological tests of the subject. 

The truckdriver failed to report background information related to his neurological 
disorder to physicians who performed his DOT physicals. Two physicians, lacking 
pertinent information, found the truckdriver to be medically qualified. The Safety Board 
concludes that the physicians who performed the truckdriver's DOT physical could not 
adequately evaluate the truckdriver's medical fitness because he did not report 
background information related to his neurological condition. 

The Safety Board has addressed the issue of improperly reported medical 
information in earlier accident reports. 33 Physicians cannot adequately evaluate the 
medical fitness of drivers unless truthful information about previous medical conditions is 
provided. Similarly, once information is given, physicians have no way to verify the 
truthfulness and completeness of answers. 

As part of the Safety Board's truck and bus safety initiative, in January 1999, the 
Board approved a series of public hearings to be conducted by its Office of Highway 
Safety. The first hearing, which took place in April 1999, focused on commercial vehicle 
oversight and crash data. As a result of the April hearing, additional Congressional 
interest, and its investigation of the May 9, 1999, crash of a motorcoach in New Orleans, 
Louisiana, that fatally injured 22 passengers, the Safety Board identified a group of issues 
that warrant additional examination: 



33 See, for example, the following reports: (Publisher and place of publication for all works cited is 
National Transportation Safety Board, Washington, D.C.) Greyhound Bus Collision with Concrete Overpass 
Support Column on 1-880, San Juan Overpass, Sacramento, California, November 3, 1973, Highway 
Accident Report NTSB/HAR-74/05 (1974); Collision ofHumbolt County Dump Truck and Klamath-Trinity 
Unified District Schoolbus, State Route 96 near Willow Creek, California, February 24, 1983, Highway 
Accident Report NTSB/HAR-83/05 (1983); Academy Lines, Inc., Intercity Bus Run-off Roadway and 
Overturn, Middletown, New Jersey, September 6, 1987, Highway Accident Report NTSB/HAR-88/03 
(1988); Greyhound Bus Lines, Inc., Intercity Bus Loss of Control and Overturn, Interstate Highway 65 in 
Nashville, Tennessee, November 19, 1988, Highway Accident Report NTSB/HAR-89/03 (1989); Factors 
ttiat Affect Fatigue in Heavy Truck Accidents, Safety Study NTSB/SS-95/01 (1995). 



Analysis 30 Hazardous Materials Accident Report 

• The safety implications of the North America Free Trade Agreement; 

• The adequacy of the OMCHS's oversight of medical fitness and drug issues as 
they relate to the commercial vehicle driver; 

• The adequacy of the CDL program; and 

• The lack of a national CDL database accessible to motor carriers for driver 
selection and hiring purposes. 

The April hearing revealed that although commercial vehicle drivers are required 
to possess a CDL and a medical certificate, often there is no verification program for the 
driver's medical fitness and drivers submit falsified certifications or, as in the case of the 
Biloxi accident, fail to inform examining physicians or the motor carriers of significant 
medical issues. Additionally, Safety Board investigations have found that examining 
physicians frequently do not understand the nature of the activities they are certifying 
drivers to perform, and no program is available to educate physicians how to conduct their 
examinations. Furthermore, medication impairment appears to be increasing among 
commercial drivers, especially in connection with combinations of prescribed and over- 
the-counter medication. Based on these findings, the Safety Board's Office of Highway 
Safety has proposed that a hearing addressing CDL and medical fitness issues be 
conducted in FY 2000. 

Applicant Screening. Despite the truckdriver's failure to report pertinent 
information on his application to Premium, the carrier's officials might have been able to 
determine his fitness for duty had they conducted the 3-year background check required 
by Federal regulations (49 CFR 391.23). The safety director verified the truckdriver's 
employment only with Fayard. The safety director told the Safety Board that he did not 
think that he would be able to obtain background information from the Navy. 

What is disturbing to the Safety Board in this case is that Premium officials did not 
even attempt to obtain Navy records. Had Premium made the information request, it may 
have obtained documents showing the truckdriver's medical history before the accident 
occurred, which may have alerted company officials that the truckdriver had a medical 
condition that could affect his skills and abilities. The Safety Board concludes that 
although a significant factor in Premium's hiring the truckdriver was his military 
background, the safety director did not attempt to check or to request the driver's military 
records, which contained useful information for determining his medical fitness and 
ability to operate heavy equipment. 

The driver also did not report his previous employment with Werner. Had he done 
so, Premium officials may have been able to question why the driver's employment with 
Werner had been terminated. The Safety Board concludes that, because the truckdriver 
failed to report on his job application his employment with a carrier that had dismissed 
him, useful information from that carrier was not available to Premium to help company 
officials evaluate the truckdriver's ability to perform his duties. 



Analysis 31 Hazardous Materials Accident Report 

At the Safety Board's April 1999 hearing, associations and motor carriers testified 
that one of their primary concerns is their ability to select competent drivers. They stated 
that drivers' records often do not transfer with them from State to State, nor do their 
records reflect all traffic violations. Motor carriers must rely on driver self-reporting to 
review prior work experience; so carriers are often unable to obtain a true picture of the 
driver's history. The Safety Board's Office of Highway Safety has therefore recommended 
that the failure of applicants to accurately report prior work history be addressed in the 
Safety Board's proposed FY 2000 public hearing. 

Employee Training 

Because of the dangers that hazardous materials pose, the drivers transporting 
them must be among the most skilled operators. In addition to having a high degree of 
general truck driving skill and experience, drivers transporting hazardous materials need 
specialized knowledge, which makes training related to specific job functions especially 
important. Drivers must not only be well-versed in the properties of their cargo and the 
rules of the road concerning the transportation of those materials but also in all proper 
handling procedures if they are to be responsible for loading and unloading. 

Premium's training program had two main phases: a 1-day orientation that 
provided new hires with a general overview of the company, the products transported, 
employee benefits, and pertinent Federal regulations, and an OJT period that focused on 
operational procedures. The OJT phase varied from 1 to 2 weeks, depending on the 
proficiency demonstrated by the new hire. In addition to the preliminary training, the 
safety director conducted quarterly safety briefings on subjects that he determined needed 
additional emphasis. 

Interviews with experienced Premium drivers and the truckdriver involved in the 
Biloxi accident revealed that the employees' knowledge of company policies and 
procedures concerning loading and unloading gasoline varied widely. The Safety Board 
therefore looked at the reference materials and instructions Premium provided to its new 
hires concerning gasoline transfers. 

The driver's manual given to Premium's new hires and the trainer's manual and 
the checksheet used by its driver- trainers were very general in nature and addressed few 
safety topics other than those concerning over-the-road transport. The manuals contained 
minimal instructions addressing gasoline transfers; the checksheet lacked detailed items 
under the category "Loading and Unloading." Although the driver-trainer said that he 
explained and demonstrated specific unloading procedures to the truckdriver, the 
truckdriver's personal notes taken during training list only very general steps and contain 
few safety considerations. 

When addressing operational considerations with serious safety implications, oral 
instructions are not sufficient. Oral instructions can be misinterpreted. Even when driver- 
trainers follow up their oral instructions by watching the drivers perform a function, there 
is no guarantee that the drivers understand the safety implications of the procedures they 
are following. Further, over time many trainees will forget instructions on procedures that 



Analysis 32 Hazardous Materials Accident Report 

they are not required to perform frequently. All drivers of cargo tank trucks therefore need 
specific written job procedures if they are to operate safely. In the case of new employees, 
in particular, well written loading and unloading procedures can establish desired work 
patterns before bad habits are learned. 

Because his operating manual lacked detailed operating instructions addressing 
cargo unloading, the truckdriver had no thorough written source to reference if he could 
not recall his driver-trainer's instructions or could not make sense of his own cryptic and 
inaccurate notes. This deficiency of information and training negatively affected the 
truckdriver's gasoline transfer activities in several ways. 

First, Premium's delivery loads to the Fast Lane stations were based on 
conservative estimates of daily gasoline sales. Consequently, circumstances such as 
unusually slow sales, shutdowns for maintenance, and miscalculations could result in the 
driver arriving with too much gasoline for the underground storage tank. Both the 
employee manual and the driver-trainer manual indicated that the driver should present 
the bill of lading to the station operator before making a transfer, but neither manual 
explains why this should be done first or identifies any potential safety benefits arising 
from this sequence. The manuals could have shown that by first obtaining the operator's 
approval of the bill of lading, the driver could determine whether he was delivering the 
gasoline to the correct location and, at facilities having tank-volume monitoring systems, 
could ascertain the actual amount of gasoline in the underground tanks before beginning 
the transfer. 

By failing to discuss the rationale for first obtaining the bill of lading signature, 
Premium lost an opportunity to emphasize to its truckdrivers the safety consequences of 
this action. Lacking this explanation, the truckdrivers apparently did not absorb the 
importance of the procedural sequence. Fast Lane personnel told the Safety Board that the 
cargo tank truckdrivers rarely, if ever, showed or discussed the bill of lading with them 
before initiating a gasoline transfer. 

Additionally, as the previous overfills at the Biloxi and the Bay St. Louis stations 
demonstrate, the gasoline cargo amounts dispatched by Premium to a location are 
sometimes greater than the available space in the underground tanks. Consequently, it is 
essential that cargo tank truckdrivers correctly determine the ullage in the underground 
storage tanks and whether the intended amount of gasoline will fit into the tank before 
beginning a gasoline transfer. Nevertheless, neither the driver nor trainer manual advised 
truckdrivers that this determination is vital to safety or provided an example showing how 
to calculate available underground storage tank space. Omission of such safety-significant 
information illustrates the inadequacy of Premium's reference manuals. 

As a safeguard against overfills, it is incumbent upon Premium to ensure that all its 
truckdrivers know the specific steps for unloading gasoline, including the various methods 
for calculating ullage in underground tanks and how to use tank charts. The truckdriver 
who overfilled Fast Lane station No. 741 in 1996 stated that he was unaware of any 
specific procedures for dealing with tanks with remote fills. Although Premium's 
management officials were aware of both this overfill and the overfill at the Bay St. Louis 



Analysis 33 Hazardous Materials Accident Report 

Fast Lane station, they still did not develop specific written procedures stressing the 
importance of calculating available space and replacing fill caps before beginning the 
transfer. Moreover, the safety director did not discuss potential procedural problems at 
stations with remote fill ports during his quarterly safety meetings. 

How a carrier manages the training of its new employees has a tremendous impact 
on their attitude toward their work and their ability to do their job effectively and 
efficiently. Inadequate instruction can leave new hires confused and uncertain of how to 
do the jobs for which they were hired. Inadequate training materials and vague procedural 
directions concerning cargo unloading procedures permit drivers to pick up bad habits and 
follow incomplete and potentially dangerous practices. 

The Safety Board concludes that Premium's operating manuals for its new 
employees and its driver- trainers lacked the specificity that employees need to ensure that 
they practice correct and safe cargo unloading procedures. The Safety Board believes that 
Premium should revise its driver and driver-trainer manuals to include specific written 
instructions on loading and unloading cargo and on the use of tools, such as storage tank 
capacity charts, necessary to deliver gasoline safely. 

But the Safety Board emphasizes that, while Premium did not provide sufficient 
training or adequate reference materials to its drivers concerning gasoline loading and 
unloading, Premium's deficiencies are symptomatic of a much larger problem in this 
area — the nationwide lack of Federal regulations addressing these significant safety 
issues. Although Federal regulations currently require that drivers be trained in loading 
and unloading procedures, the regulations do not require that motor carriers of bulk 
hazardous materials maintain specific written loading and unloading procedures. The 
Safety Board concludes that, to help drivers follow safe loading and unloading 
procedures, Federal regulations should require carriers that transport hazardous materials 
in cargo tanks to have specific written procedures for loading and unloading. The Safety 
Board therefore believes that RSPA should promulgate regulations requiring motor 
carriers that transport hazardous materials in cargo tanks to develop and maintain specific 
written cargo loading and unloading procedures for their drivers. Once regulations are 
promulgated, the FHWA should ensure that the motor carriers are in compliance with the 
regulations. 

The Biloxi accident presents issues relevant to all carriers involved in the transport 
of gasoline and petroleum products. The Safety Board therefore believes that the National 
Tank Truck Carriers Association and the American Petroleum Institute should inform their 
members of the facts and circumstances of the Biloxi accident and urge them to review the 
adequacy of their procedures for hiring and training truckdrivers and their written 
procedures for loading and unloading hazardous materials. 

Adherence to Policy 

The Safety Board is also concerned by the failure of Premium management to 
adhere to its own clearly stated policies and procedures. The record of the truckdriver 
involved in the accident showed a regular pattern of Federal hours-of-service violations. 



Analysis 34 Hazardous Materials Accident Report 

Although the Premium driver's manual states that suspension is the consequence of failing 
to comply with these Federal regulations, company officials merely continued to issue the 
truckdriver written warnings as a disciplinary measure rather than suspending him. 

Additionally, carrier officials failed to follow their own written procedures when 
they retained the truckdriver after the driver-trainer recommended termination. According 
to the Premium driver-trainer manual, the driver-trainer with whom a new employee is 
teamed has the final determination on the length of the driver's initial training and on 
whether the new hire should be advanced to the status of qualified driver or terminated. In 
this case, the truckdriver's trainer had determined the truckdriver's unsuitability by their 
fourth day of working together. Instead of terminating the truckdriver as recommended by 
the driver-trainer, the safety director told the driver-trainer to take the truckdriver out 
again. The driver-trainer spent one more day of training with the truckdriver but believed 
that the truckdriver was not ready to work by himself. The driver-trainer had anticipated 
having two or three additional days to work with the truckdriver; however, while the 
driver-trainer was off-duty, company officials allowed the ill-prepared driver to make a 
delivery alone. The Safety Board concludes that the Premium safety director failed to 
adhere to company procedures for hiring and training the truckdriver and for disciplining 
him when he failed to comply with the hours-of-service requirements. The Safety Board 
believes that Premium should establish procedures to ensure that company officials adhere 
to written policies relating to hiring, training, and disciplining of company truckdrivers. 

Dispatch Procedures 

On the evening of August 8, 1998, during the telephone conversation between the 
safety director, who was serving as dispatcher, and the truckdriver, a miscommunication 
occurred that resulted in the truckdriver erroneously making a delivery to station No. 741. 
A review of the dispatch sheet and of statements made by the safety director indicated that 
the delivery was intended for a station in Long Beach, Mississippi. 

The safety director claimed to have correctly dispatched the truckdriver, and the 
truckdriver claimed to have accurately recorded the dispatches he was given. The 
miscommunication demonstrated that Premium's dispatching procedures lack safeguards 
against errors. Both the safety director and the operations manager stated that they and 
other dispatchers had sometimes made errors in relaying information to truckers. Despite 
the fact that all company dispatches were given over the telephone and truckdrivers never 
saw the written assignments before delivery, the company dispatch procedures lacked 
safeguards for ensuring that truckdrivers received the correct information about the type, 
amount, and destination of the gasoline to be delivered. The Safety Board concludes that 
Premium's lack of adequate procedures for verifying the accuracy of dispatch orders 
resulted in the truckdriver delivering gasoline to the wrong location. The Safety Board is 
pleased to learn that, since this accident, Premium has revised its dispatch procedures to 
include methods by which the dispatcher may verify that the driver has received the 
correct delivery information. 



Analysis 35 Hazardous Materials Accident Report 

Adequacy of Fast Lane Employee Training 

The Fast Lane employees at station No. 741 interviewed after the accident 
indicated that they were busy with various routine activities during their work shift on the 
night of the overfill. They also indicated that they had become accustomed to hearing the 
overfill alarm and no longer responded to it. 

The EPA not only requires facility owners and operators to verify before transfer 
operations begin that the amount of gasoline being delivered will fit into underground 
gasoline storage tanks, it also requires that owners and operators monitor the transfer. The 
EPA allows owners and operators the option of using monitoring equipment, such as the 
Red Jacket™ system, to satisfy this Federal requirement. 

According to Morrison, the owner of Fast Lane station No. 741, its employees are 
not trained to monitor the Red Jacket™ system during transfer nor are they trained to 
respond to the Red Jacket™ overfill alarm. Morrison officials stated that, because of their 
agreement with Premium, they considered the carrier responsible for determining that the 
volume of cargo being delivered would fit in the underground tanks. 

The Safety Board is concerned by this attitude. The EPA requires that station 
owners and operators ensure that underground storage tanks have available space for the 
gasoline being delivered and that the transfer operation is monitored. The safest and most 
effective way to accomplish this is for station employees to work with truckdrivers to 
ensure the safe execution of gasoline deliveries. The Safety Board concludes that Fast 
Lane employees lacked adequate procedures and training to prevent overfills of the 
underground storage tanks. Morrison did not require its Fast Lane employees either to 
determine whether the amount of gasoline intended for delivery would fit in the 
underground storage tanks or to monitor alarms warning that the tanks were nearing 
maximum fill levels during cargo transfers. The Safety Board believes that Morrison 
should establish procedures and provide training to ensure that its employees verify that 
underground storage tanks have sufficient capacity for the gasoline or other petroleum 
products offered for delivery and monitor such transfer so that overfills do not occur. 

The Safety Board doubts that the failure to require station employees to monitor 
the gasoline transfer process is limited to Morrison. Accordingly, other station owners 
need to be made aware of the potential problems of relying on the hazardous materials 
carrier to safely load and unload gasoline. The Safety Board is convinced that industry 
associations should promote improved safety at service stations by publicizing the 
problems identified in the Biloxi accident. The Safety Board therefore believes that the 
National Association of Convenience Stores, the National Association of Truck Stop 
Operators, the Petroleum Marketers of America, the Service Station Dealers of America, 
and the Society of Independent Gasoline Marketers of America should inform their 
members of the facts and circumstances of the Biloxi accident and urge them to review 
their procedures and, if necessary, to revise them to require that station employees verify 
that underground storage tanks have sufficient capacity for gasoline or other petroleum 
products offered for delivery and to monitor such transfers so that overfills do not occur. 



Analysis 36 Hazardous Materials Accident Report 

Adequacy of EPA Enforcement 

The EPA has very clear requirements stipulating that facility owners and their 
operators should ensure that the amount of gasoline delivered will fit into underground 
storage tanks. In December 1997, the Mississippi DEQ conducted an inspection at Fast 
Lane station No. 741 and noted no significant violations at that time. However, the 
inspectors did not check to determine whether the facility owner had trained or was 
requiring his employees to monitor transfers to the underground storage tanks. Following 
the 1998 overfill and fire, DEQ inspectors visually inspected the site to determine whether 
the top of the tank had loose fittings that may have caused or contributed to the release 
from the underground storage system. They found that all the fittings appeared to be tight. 

From interviews with Federal EPA officials and Mississippi DEQ staff, the Safety 
Board determined that neither the Federal nor the State agency has enforced the 
requirement that facility owners or operators determine the available underground storage 
space and monitor transfer procedures as required by 40 CFR 280.30. The EPA's programs 
have focused on equipment safeguards and preventing underground storage tank leaks. 
The Safety Board concludes that the EPA's program for preventing underground storage 
tank releases has not adequately addressed the requirements in 40 CFR 280.30 for 
preventing overfills of the type that occurred in Biloxi. 

Had the owner of Fast Lane station No. 741 required his employees to determine 
whether the amount of gasoline intended for delivery would fit into the underground 
tanks, the Biloxi accident probably would not have occurred. The Safety Board believes 
that the EPA should take action to improve compliance with and enforcement of 40 CFR 
280.30, which requires that owners and operators of underground storage tanks prevent 
their overfilling. 

Accident Notification Requirements 

Premium did not notify the NRC until nearly 24 hours after the accident. The 
delayed notification precluded the Safety Board and other Federal agencies from 
responding promptly and initiating the accident investigation. 

Under reporting criteria at 49 CFR 171.15, a carrier that transports hazardous 
materials is required to provide telephonic notification "at the earliest practical moment." 
However, the phrase "the earliest practical moment" is not defined in the hazardous 
materials regulations, nor has RSPA issued an interpretation that provides any time 
constraints on the reporting time frame. The Safety Board itself requires railroads under 
49 CFR 840.3 to provide telephonic notification through the NRC not later than 2 hours 
after an accident resulting in a fatality, the release of hazardous materials, or an evacuation 
of the public and not later than 4 hours after an accident resulting in damages exceeding 
specified thresholds. Similarly, OSHA requires notification within 8 hours of the death or 
in-patient treatment of any employee following a work-related accident. The Safety Board 
concludes that the effectiveness of requirements for telephonic notification of certain 
hazardous materials accidents would be strengthened if the requirements contained a 



Analysis 37 Hazardous Materials Accident Report 

specified time frame. The Safety Board believes that RSPA should require that a 
hazardous materials incident meeting the immediate notification requirements in 49 CFR 
171.15 be reported within a specified time period to Federal authorities. 



38 Hazardous Materials Accident Report 



Conclusions 



Findings 

1. The Premium Tank Lines, Inc., truckdriver was not impaired by drugs, alcohol, or 
fatigue on the morning of the Biloxi, Mississippi, accident. 

2. The physicians who performed the truckdriver's U.S. Department of Transportation 
physical could not adequately evaluate the truckdriver's medical fitness because he did 
not report background information related to his neurological condition. 

3. Although a significant factor in Premium Tank Lines, Inc.'s hiring the truckdriver was 
his military background, the safety director did not attempt to check or to request the 
driver's military records, which contained useful information for determining his 
medical fitness and ability to operate heavy equipment. 

4. Because the truckdriver failed to report on his job application his employment with a 
carrier that had dismissed him, useful information from that carrier was not available 
to Premium Tank Lines, Inc., to help company officials evaluate the truckdriver's 
ability to perform his duties. 

5. The Premium Tank Lines, Inc.'s safety director failed to adhere to company 
procedures for hiring and training the truckdriver and for disciplining him when he 
failed to comply with the hours-of-service requirements. 

6. The Premium Tank Lines, Inc.'s operating manuals for its new employees and its 
driver-trainers lacked the specificity that employees need to ensure that they practice 
correct and safe cargo unloading procedures. 

7. To help drivers follow safe loading and unloading procedures, Federal regulations 
should require carriers that transport hazardous materials in cargo tanks to have 
specific written procedures for loading and unloading. 

8. Premium Tank Lines, Inc.'s lack of adequate procedures for verifying the accuracy of 
dispatch orders resulted in the truckdriver delivering gasoline to the wrong location. 

9. Fast Lane employees lacked adequate procedures and training to prevent overfills of 
the underground storage tanks. R. R. Morrison and Son, Inc., did not require its Fast 
Lane employees either to determine whether the amount of gasoline intended for 
delivery would fit in the underground storage tanks or to monitor alarms warning that 
the tanks were nearing maximum fill levels during cargo transfers. 



Conclusions 39 Hazardous Materials Accident Report 



10. The Environmental Protection Agency's program for preventing underground storage 
tank releases has not adequately addressed the requirements in 40 Code of Federal 
Regulations 280.30 for preventing overfills of the type that occurred in the August 9, 
1998, accident in Biloxi, Mississippi. 

11. The effectiveness of requirements for telephonic notification of certain hazardous 
materials accidents would be strengthened if the requirements contained a specified 
time frame. 

Probable Cause 

The National Transportation Safety Board determines that the probable cause of 
the accident was the failure of Premium Tank Line, Inc.'s officials to follow established 
company procedures in hiring and training new drivers, the company's lack of adequate 
procedures for dispatching drivers and delivering cargo to customer facilities, and the 
failure of R.R. Morrison and Son, Inc., to have adequate safety procedures for accepting 
product offered for delivery at its Fast Lane stations. Contributing to the accident was the 
truckdriver's various and numerous operating errors during the gasoline transfer process 
that led to the underground storage tank overfill. 



40 Hazardous Materials Accident Report 



Recommendations 



As a result of its investigation, the Safety Board makes the following safety 
recommendations: 

To the Research and Special Programs Administration: 

Promulgate regulations requiring motor carriers that transport hazardous 
materials in cargo tanks to develop and maintain specific written cargo 
loading and unloading procedures for their drivers. (H-99-57) 

Require that a hazardous materials incident meeting the immediate 
notification requirements in 49 Code of Federal Regulations 171.15 be 
reported within a specified time period to Federal authorities. (H-99-58) 

To the Federal Highway Administration: 

Once the Federal regulations requiring motor carriers that transport 
hazardous materials in cargo tanks to provide written cargo loading and 
unloading procedures are promulgated, ensure that the motor carriers are in 
compliance with the regulations. (H-99-59) 

To the Environmental Protection Agency: 

Take action necessary to improve compliance with and enforcement of 40 
Code of Federal Regulations 280.30, which requires that owners and 
operators of underground storage tanks prevent their overfilling. (H-99-60) 

To Premium Tank Lines, Inc.: 

Revise your driver and driver- trainer manuals to include specific written 
instructions on loading and unloading cargo and on the use of tools, such as 
storage tank capacity charts, necessary to deliver gasoline safely. (H-99-61) 

Establish procedures to ensure that company officials adhere to written 
policies relating to hiring, training, and discipline of company truckdrivers. 
(H-99-62) 

To R.R. Morrison and Son, Inc.: 

Establish procedures and provide training to ensure that your employees 
verify that underground storage tanks have sufficient capacity for the 



Recommendations 41 Hazardous Materials Accident Report 

gasoline or other petroleum products offered for delivery and monitor such 
transfers so that overfills do not occur. (H-99-63) 

To the National Association of Convenience Stores, the National Association of Truck 
Stop Operators, the Petroleum Marketers of America, the Service Station Dealers of 
America, and the Society of Independent Gasoline Marketers of America: 

Inform your members of the facts and circumstances of the August 9, 1998, 
accident in Biloxi, Mississippi, and urge them to review their procedures 
and, if necessary, to revise them to require that station employees verify 
that underground storage tanks have sufficient capacity for gasoline or 
other petroleum products offered for delivery and to monitor such transfers 
so that overfills do not occur. (H-99-64 through -68) 

To the National Tank Truck Carriers Association: 

Inform your members of the facts and circumstances of the August 9, 1998, 
accident in Biloxi, Mississippi, and urge them to review the adequacy of 
their procedures for hiring and training truckdrivers and their written 
procedures for loading and unloading hazardous materials. (H-99-69) 

To the American Petroleum Institute: 

Inform your members having cargo tank motor carrier operations of the 
facts and circumstances of the August 9, 1998, accident in Biloxi, 
Mississippi, and urge them to review the adequacy of their procedures for 
hiring and training truckdrivers and their written procedures for loading 
and unloading hazardous materials. (H-99-70) 



BY THE NATIONAL TRANSPORTATION SAFETY BOARD 

JAMES E. HALL JOHN A. HAMMERSCHMIDT 

Chairman Member 

ROBERT T. FRANCIS II JOHN J. GOGLIA 

Vice Chairman Member 

GEORGE W. BLACK, JR. 

Member 

Adopted: September 21, 1999 



43 Hazardous Materials Accident Report 



Appendix A 

Investigation 



The National Transportation Safety Board was notified about 12:30 a.m. eastern 
daylight time on August 10, 1998, of an overfill and fire at a gasoline station-convenience 
store in Biloxi, Mississippi. The investigator-in-charge and other members of the Safety 
Board investigative team were dispatched from the Washington, D.C., headquarters office. 
Upon arriving on scene, the Board established investigative groups to study hazardous 
material factors, vehicle factors, carrier operations, human performance, emergency 
response, and survival factors. 

The Safety Board was assisted in the investigation by the Federal Highway 
Administration, the Mississippi Public Service Commission, the City of Biloxi, Premium 
Tank Lines, Inc., and R.R. Morrison and Son, Inc. 



44 Hazardous Materials Accident Report 



Appendix B 

Driver-Trainer's Checksheet 



The following pages show photocopies of the two-page checklist used by 
Premium's driver-trainers during a new hire's OJT. 



Appendix B 



45 Hazardous Materials Accident Report 



Terminal. 
Driver 



DRIVER TRAINERS CHECK LIST 
Dale Products. 



Trainer. 



Tractor/1 raller No. 



Driver Trainer's Remarks 



TRACTOR 
t How lo check Brafcr System lor ilr leaks 

2. How lo release Park Brake when ■ loss ol air occurs 

3. How (o use crutch Drake 

4 How lo manually operale ran Clutch 

5 How to bleed ilr Irom pump when air block causes pump nol lo 
unload 



RAILER 

Remole Control lor closing emergency valve 

Where Calibration charts are carried and how lo use Ihrm 

Check unloading ling valve belore moving, cap lo be sure It Is closed.. 

Fusible links and what they are 

How to placard trailer 



I. PRE-TRIP INSPECTION 

A. Uses slandard truck check procedure. 

(I) Checks water. (2) Checks off. (3) Checks fuel, leaves hood 
up. Starts engine, Idles 550 RPMs while ofl pressure builds up. 
Increase! lo 900 RPMs while checking; unit. (4) Turns on 
tights. Checks lights. Cleans lights and reflectors. (5) Checks 
tires. (6) Checks wheels and lugs. (7) Checks springs & Irame 
tor cracks (8) Checks unloading hose. (9) Checks landing 
gear. (10) Checks filth Wheel Latch. Brake Hose, light Cord, 
and Connecllons. (11) Checks tool bo*. (12) Checks & cleans 
mirrors, windows. S windshield. (13) Checks horn & panel 
gauges. |I4) Checks windshield wipers. (15) Checks steering 
lor looseness. (16) Checks brakes, service S park. 
(17) Checks emergency equipment, fire extinguishers and 
reflective triangles. (18) Checks fusible nuts or finks In Una to 
the Internal valves. (19) Checks placards Ind Holders 

II. 9TARTIN0 ENGINE 

A. Depresses clutch pedal before starling engine 

B. Releases sorter button as soon «s engine starts 

C. Checks air pressure and olher Instruments 

D. Builds up 60 lbs. air pressure belore moving vehicle 

iii. starting; vehicle 

A. Observes pedestrians and checks Iralflc tondltlons belore 
slarllngoul. 

B. Selects proper ocar (low gear when loaded) 

C. Doesn't tact engine 

D. Starts smoothly Irom standstill, dotsn'l allow unit lo roll back 
on hills 

E. Ooesn'l slat engine 



On* I 

HOr PlHorlWd 

Sttblidortr 



CLUTCHING AND SHIFTING 

A. Doesn't ride clutch 

B. Ooesn'l stay In low gears loo long 

C. Doesn't slay In high gears too long, doesn't lug engine 

0. Altalns proper speed belore shilling up 

E. Ooesn'l over speed engine when shitting up 

F. SMfls gears skillfully (double clutch and doesn't clash Ihem). 

0. Ooesn'l slip clutch to keep unll Irom rolling back on a gride.. 
H. Selects proper gears — upgrade, downgrade, on level. 

1. Doesn't coast down gride or lo I stop 



Oi. t l rirrn 

WITl.lo.nwd 



STEERING AND POSITIONING 

A. Places hands In stable position on wheel, uses both hands.. 

B. Steers smoothly, not abruptly 

C. Ooesn'l ride center Une 

D. Doesn't weave oil onto shoulder 

E. Slays In proper lane on htfls & curves 

F. Slays welt to the right when being passed 

0. Ooesn'l use turning signals lo get other vehicles lo pass 

H. Slays In proper lane It Inlflc lights and stop signs 



VI. SPEED CONTROL 

A. Varies speed lo meel conditions safely, especially when ap- 
proaching schools, curves, and bflnd Intersections 

B. Maintains safe distance when loltowlng other vehicles, one 
unll length tor ever 10MPH 

C. Uses lime Interval lo check distance 

0. Is alert to narrow tunnels and bridges: permits other vehicles 

lo pass through 

E. Is alert lo people ind livestock on or near roadway 

f. Observes posted speed flmlt 



Time Training: Start 



C«s) 



Appendix B 



46 



Hazardous Materials Accident Report 



dud lumi 
HOT Ptrtanm 

SgulJlcu-vy 



VII. PASSING OTHER VEHICLES 

A. Checks la nuke suit toad Is clear ahead anil behind before 

pulling cul 

B Doesn't piss on hills, curves, bridges, Intersections, or In 

congested areas 

C. Uses goud lodgement In deciding when la pass 

0. Sounds horn well in advance; al nighl dishes lights 

E. Cuts* back Inlo tins soon alter passing without culling In on 

vehicle being passed 

f . Doesn't loilow loo close belori passing 

Q Does not pass by weaving through Ualftc 

H. Uses turning signals lor moving Irom lane la lane 

1. Is alert lu vehicles parked on o/ near the roadway thai may pull 



out. 



VIII. UAKIHQ TURNS 

A Pulls gradually and safely Inlo proper Una, well in advance of 



turn 



B Gives proper signal al leasl 100 feel In advance ol turn 

C Is aleri lor cars lo come between vehicle and curb when mak- 
ing lurns 

D. Mikes ceilain way Is clear belori entering Intersection 

(. Makes turn al proper speed (not loo last or loo slow) 

f. Doesn't sciape tires against curb 

IX. RAILROAD CROSSINGS 

A. Comes lo a lull slop al crossing - uses 4-way flasheri 

8. Looks in M directions beiore crossing 

C. Slults to proper gear beiore getting lo crossing and does not 
shill geais on crossing 

X. DRIVING AT NIGHT 

A Doesn't uveidiive headllghls 

6 Guides uir nght side ol road when approaching Uafllc with 

bright lights 

C. Dims kghis lor approaching Iralllc 

D Dims lights alter being passed and when lollowlng other 

vehicles 

£. Does not onvi loo lasl In fog or smoke II nlghl or day 

XI. STOP STREET AND TRAFFIC LIGHTS 

A. Comes lu j lull slop 

8 Doesn't over tun cross walk 

C. Slops in uusiuon lo see roadway lorlghl and lefl 

Doesn't ciuwd pedestrians or other vehicles (doosn'l blow 
horn al uiiiurs) 

E. Doesn't g j through trallic light on red 

f Doesn't i jcu motor while waning al traffic Ughl or slop sign 



00 



Quel llcuil 
NOT PirtuincJ 
SlUllclolrif 

XII. UNCONTROLLED INTERSECTIONS OR THRU STREETS 

A. Slows down; Hops il necessary 

8. looks In all directions 

C. Yields righlol-way whenever Ihere Is any question 

XIII. STOPPING VEHICLE 

A. Anticipates slops, iJIowj molor to slow vehicle down 

B Brakes equipment smoothly (doesn't make quick stops accept 

In emergency) 

C. Doesn'l slop loo closa to other vehicles In Iralflc 

XIV. PARKING VEHICLE 

A. Gels claar of roadway 

B. Puts unit In low guar (leaves slop oul) 1 sals parking broke; 
chocks wheels, U necessary 

C. Turns wheels toward curb on downgrades and away Irom 

curbs on upgrades 

D. Doesn't leave molor running 

£. Doesn'l park with trailer brake or tractor protection valve 

XV. BACKING 

A. Slops In correct position to back 

8. Goes lo rear ol vehicle beiore backing 

C. Backs smoothly 

XVI. LOADING AND UNLOADING 

A. Doesn'l unload before checking address ol customer with ad- 

dress on blO of lading 

8. Doesn'l break seals or unload until customer has Initialed bill 

ol lading A Inspected load 

C. Hooks up ground wrra (il required) 

D. Unloads al proper engine RPS (pump or lurbo conveyor) 

I Slays with unit; stands by product control valve. (Driver con- 

l/otled loading and unloading) 

f . Depresses clutch pedal when engaging or disengaging power 

lake off 

G. Drains Into bucket belora leaving customer premises (when 

required) 

H After unloading, checks from lop lo see Uial lank is amply and 

lumens dome covers 

I. Wears long sleeve shirl and safely clothing, when required 

XVU. MISCELLANEOUS 

A. Mainlains naal appearance 

B. Maintains courteous conduct In terminals and on customer's 
premises — 

C. Chucks tires beiore trip and al each slop Tires must be check- 
ed at leasi every 2 hrs. or 100 miles 

D. Aliur changing tire, checks lugs alter traveling no more than 

20 miles 



47 



Hazardous Materials Accident Report 



Abbreviations and Acronyms 



ADD attention deficit disorder 

ANPRM Advance Notice of Proposed Rulemaking 

API American Petroleum Institute 

CDI Commercial Driver Institute, Inc. 

CDL commercial drivers license 

CFR Code of Federal Regulations 

CVSA Commercial Vehicle Safety Alliance 

DOT U.S. Department of Transportation 

EPA Environmental Protection Agency 

FHWA Federal Highway Administration 

FRA Federal Railroad Administration 

hazmat hazardous materials 

MPSC Mississippi Public Service Commission 

MVR motor vehicle record 

OJT on-the-job training 

OMCHS Office of Motor Carrier and Highway Safety 

OSHA Occupational Health and Safety Administration 

NRC National Response Center 

RSPA Research and Special Programs Administration 

UST underground storage tank 



DATE DUE 



<?7'S3- 



HE 199.5 .D3 U581 99/02 
Overflow of gasoline and 
fire at a service 
station-convenience store 



HE 199.5 .D3 U581 99/02 
Overflow of gasoline and 
fire at a service 
station-convenience store 

NATIONAL EMERGENCY 

TRAINING CENTER 

LEARNING RESOURCE CENTER 

16825 SOUTH SETON AVENUE 

EMMITSBURG, MD 21727 




035798 



^7/5^° 



^7/55* 



NATIONAL TRANSPORTATION SAFETY BOARD 
Washington, D.C. 20594 



Official Business 

PENALTY FOR PRIVATE USE, WOO